Last week, the HIT Policy Committee responded to CMS’ proposed meaningful use regulations, clearly unhappy that CMS had chosen to ignore some of their recommendations and had even added some of its own. At first blush, it appeared that the Policy Committee had come to recognize how overwhelmingly burdensome the requirements are for physicians, in that they proposed the introduction of some flexibility to the requirements. They recommended allowing physicians to defer, from Stage 1 to Stage 2, up to five of the 25 required measures. However, at the same time, committee members reaffirmed their commitment to CPOE (Computerized Physician Order Entry)—a measure that many physicians cite as one of the requirements that would keep them from even considering participation in the EHR program.
Even if CMS were to agree to grant some general flexibility, the committee was adamant that CPOE remain mandatory right from the start, (i.e., not deferrable to 2013), and that the data entry be done directly by the ordering provider. Adding to the burden that the 25 measures already impose on physicians, the committee also recommended the reinstatement of some of the most onerous requirements—documenting a progress note; stratifying quality reports by race, gender, language, insurance class, etc.; and recording advance directives, just to name a few. This sends a strong signal to physicians about where their interests rank among those of the various other stakeholders.
It’s easy to get sidetracked by the details of meaningful use, but with that as a focus, one loses sight of the forest for the trees. The government continues to ignore the fundamental problem that has discouraged EHR adoption in the past, particularly for high-volume, community-based specialists—and that is the EHR products themselves. The government has created an unstable program, basing it on unproven, difficult-to-use, traditional EHRs, and then has imposed additional layers of complexity on top of these products. First, EHR vendors will have to rush to modify their products to meet HHS certification requirements, resulting in even more cumbersome EHR products. Then, over the next five years, they will have to constantly hustle to keep up with the continuously evolving meaningful use criteria, as well as implementing the Y2K-like conversion from ICD-9 to ICD-10. In the technology world, rushing development efforts to meet unrealistically aggressive timeframes typically results in unusable and clumsy software. Unfortunately for physicians, the government will expect them to use these more complex EHRs to meet onerous meaningful use requirements that become increasingly stringent from 2011 to 2013 and 2015.
Regardless of whether Stage 1 meaningful use is ultimately made a little harder or a little easier, the fact remains: trying to earn the government’s EHR incentives will severely impact physician productivity. High-volume physicians, who in the future will be expected to see more patients at lower reimbursement rates, need to identify and adopt productivity-enhancing—not productivity-sapping—EHR solutions.
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This governmental refusal to be practical and pragmatic in it’s rush to EMR will be yet another impetus for early physician retirement. It’s not as if Medicare doesn’t already overburden every physician office in the country with mandates and paperwork. Many of us are on the brink of quitting anyway – this will just make that possibility a certainly rather than a likelihood.
Aside from all the meaningful use talk, I haven’t heard anything spoken about the cost to physicians of data storage. Where will all the data be strored? Photographs, radiology images, pathology images, and everyday notes and procedure notes. Will doctors have to pay vendors to store data? How much will that cost as the data builds up over time?