February 4th, 2011
Yesterday morning, in a podcast interview with Neil Versel, a respected HIT journalist, I was asked to compare the mood at last year’s HIMSS meeting with my expectations for this year’s assembly. In 2010, I listened as David Blumenthal, head of ONC, spoke to a standing-room-only crowd, whipping up a frenzy of excitement about ARRA and its EHR incentives in what I can only describe as a pep rally. I told Neil that I anticipate a more subdued and somewhat anxious atmosphere at this year’s meeting, since the practical realities and challenges associated with the complexities of meaningful use have set in. A recent survey of hospital CIOs, for example, revealed reduced confidence in the ability of their respective institutions to successfully meet the requirements within the allotted timeframes, and a resulting skepticism about whether they would earn the incentives. Similarly, at the recent 2-day hearings conducted by the Adoption and Certification Workgroup, the generally positive sentiment was tempered by concerns about operational issues, timing, IT workforce challenges, and the multitude of government programs on the plates of practices.
Then, yesterday afternoon, the news broke that David Blumenthal is stepping down from his post as the national leader of the EHR adoption and incentives program. Although we all know that no single individual is ever indispensible, the timing of his departure struck me as quite odd. The program is at the precipice—its launch is just underway and the first attestations of meaningful use are expected in April. Initial success or failure will be evidenced imminently. One would think that this would be the time to demonstrate stability and unwavering commitment from the top down—a time to rally all of the forces to ensure the program’s success.
I cannot help wondering the following:
- Why is Blumenthal stepping down now, when the program is at such a critical juncture?
- Why is HHS Secretary Sebelius just now “conducting a national search for the right successor” even though she reports that it was always the plan that Dr. Blumenthal would end his term at this point?
- What are the implications for the EHR incentives program?
- Will his departure affect the likelihood of its success?
- How will provider confidence in the program be impacted?
- Should we expect changes in the program? What kind of changes?
Please share your thoughts on David Blumenthal’s departure by commenting below.
January 19th, 2011
The response to last week’s Meaningful Use IQ Test revealed a tremendous thirst for information and a fair amount of confusion about the facts and realities of meaningful use. Neither was terribly surprising, given the recent hype surrounding the program’s launch and the complexity of the regulations.
Since the quiz was posted last week, 534 people have taken the test. The average score was 56% (see chart below and the breakdown of responses at the bottom of the page). These results mean that physicians will need a great deal of assistance from consultants, Regional Extension Centers, and vendors to succeed in their pursuit of the EHR incentives. If that aid is not forthcoming, there could be a large number of very disappointed providers when the incentives are distributed.
The following are some observations:
- Only a small minority of our test-takers (9%) appear to truly understand the regulations and the requirements in their entirety. (Inga, from HIStalkPractice.com is one of the few who just might—based on her perfect score!)
- Many people find the intricacies of the regulations baffling—as indicated by more than half of the respondents (300 of 534) knowing half or less of the information.
- The fact that over one-third of the respondents did not know that providers cannot collect Medicare EHR incentives and Medicare ePrescribing incentives in the same year—no “double dipping” allowed—means that they have likely not analyzed their options to maximize the total revenue from the two incentive programs.
- I thought it was interesting that nearly half of the respondents thought that the program requires reporting on only Medicare and Medicaid patients, when, in reality, the government is requiring providers to submit data on all patients.
- Clearly, the message has come through that the program has been made more specialist-friendly, as physicians will be able to exclude measures that are not relevant to their practices. However, many do not understand how these exclusions factor into the demonstration of meaningful use.
The Meaningful Use IQ Test is still active, so if you haven’t accepted the challenge yet, you can still do so. I’m glad that it is raising awareness and providing valuable education. That was precisely its purpose!
January 13th, 2011
Now that the EHR incentive program has officially begun, physicians and practice managers are taking a closer look at the meaningful use requirements and the rules for participation. At my company, we have been fielding an increasing number of questions about meaningful use, and it is clear that the complexity of the regulations has created a fair amount of confusion.
See how well you understand meaningful use. Challenge yourself: Check your knowledge by taking this quiz, and learn some important information in the process. Comments are welcome.
January 5th, 2011
The results of a recently released UC Davis study on the effect of EMR adoption on physician productivity say a lot about the impracticality of trying to impose one EHR solution on an entire healthcare delivery system. Although this study was limited in its focus—primary-care providers within an academic medical center—its implications are even greater when applied to specialists, and magnified exponentially when extended to community-based, private-practice physicians.
The researchers at UC Davis were not surprised with their findings that the initial implementation of EMR technology resulted in a 25% to 33% decline in physician productivity, but what they did find surprising was that the results varied widely by medical discipline. While internal medicine physicians regained—and slightly increased—their prior productivity over time, pediatricians and family practice physicians did not, “even after they had climbed the learning curve.” The study’s conclusion was that inherent differences in workflows create varied needs for EHR technology and that “One size does not fit all.”
If one EHR cannot satisfy the needs of different types of primary-care physicians, clearly that EHR cannot be expected to meet the needs of specialists whose workflow is very different, driven by different types of patients and care. It is foolish to expect that a hospital can impose on its physicians the EHR that meets its needs and expect that it will also meet theirs. This is particularly true with community-based, private-practice physicians, whose incomes are tied to their productivity. Physicians understand the productivity impact of the wrong EHR and will resist.
An anticipated positive outcome of the government’s goal of interoperability, which it is trying to achieve through the establishment of EHR standards, should be that providers will be able to adopt the software that best meets their needs and not have to conform to another provider’s preference. One size will no longer be expected to fit all.
December 16th, 2010
The number of different government programs, and the length of the rules that describe how to take advantage of each of them, can be overwhelming. But one thing is eminently clear: the importance of ePrescribing in 2011. There are three compelling reasons to ePrescribe in the coming year:
Physicians can earn a 1% bonus on their 2011 Medicare revenue. Aside from the patient-care and physician-efficiency benefits that ePrescribing offers, ePrescribing on at least 25 unique Medicare encounters in 2011 will qualify a physician for an additional 1% of that year’s Medicare Part B Fee-for-Service revenue under MIPPA (Medicare Improvements for Patients and Providers Act). That money would be received in the fall of the following year.
2011 ePrescribing activity protects physicians from the Medicare ePrescribing penalties in 2012 and 2013. Odd as it sounds, while bonuses for 2012 and 2013 will be based on successful ePrescribing in each of those years, penalties for those years will be assessed based on 2011 activity. To avoid penalties in 2012, (1% of Medicare revenue), physicians must report ePrescribing on 10 unique Medicare encounters between January and June, 2011. To avoid penalties in 2013 (1.5% of Medicare revenue), physicians must report at least 25 times during the full 2011 year.
ePrescribing is a great way to begin the transition to an EHR, particularly if a physician intends to participate in the EHR incentives program (ARRA). ePrescribing is an integral part of the Meaningful Use requirements and—with the right software—a great way to begin the transition to a digital office.
Based on the above, I offer a few strategies for consideration. The rules, and the interplay between them, have created a number of consequences, that intended or not, can be used by physicians to their financial advantage:
It is important to start ePrescribing early in 2011. Ironically, even if a physician meets the 25-prescription minimum and earns the 2011 incentive, he or she would still be subject to a penalty in 2012 if that ePrescribing activity—no matter how extensive—occurs only in the second half of the year. So at a minimum, ePrescribe 10 times in the first half of the year and 15 times in the second half.
Since the rules (MIPPA and ARRA) do not allow collecting under both programs during the same year, physicians can maximize the combined revenue by earning the ePrescribing bonus in 2011, and waiting to begin participation in Meaningful Use until 2012. Beginning in 2012 still allows a physician to qualify for the full 5 years of EHR incentives ($44,000 as a Medicare provider).
Another irony is that, although ePrescribing is integral to ARRA, it is possible to satisfy the measures for one program and not satisfy the requirements of the other in any particular year. The requirements differ, and the onus is on the physicians to meet each set of rules to qualify for the respective incentives.
As confusing as the above appears, it is actually even more so, because there are also some exceptions. Not surprisingly, there are organizations (MGMA and AMA, for example) actively petitioning the government to reconsider the basis for 2012 and 2013 ePrescribing penalties and asking for harmonization of the MIPAA and ARRA regulations. For further information on the implications for your practice, I invite you to take advantage of the educational resources available through SRSsoft by calling our Government Affairs Department: 201-802-1300 X 1229.
December 13th, 2010
In an unusual display of bipartisanship, Congress made it clear that they have no intentions of cutting physician reimbursement—even in a time when the country is facing severe economic challenges. By unanimous consent, the Senate passed the Medicare and Medicaid Extenders Act of 2010, extending Medicare rates through the end of 2011 and preventing the threatened 25% cut that was to go into effect on January 1. The following day, the House of Representatives passed the payment fix by an overwhelming (nearly unanimous) vote of 409 to 2, and President Obama’s signature is expected imminently.
Physicians should feel reassured that the uncertainty and concern that the SGR formula creates each year—and no doubt will until the calculation is redefined—should be tempered. This year’s resolution, albeit not an increase, can be taken as an indication that the annually feared drastic reductions are not likely. Physicians can now plan accordingly and make business decisions and capital investments that enable practice growth.