Meaningful Use Stage 2: Speak Now, or Forever Hold Your Peace

Meaningful Use Stage 2: Speak Now, or Forever Hold Your PeaceYesterday, the Proposed Rule defining Meaningful Use Stage 2 was officially posted in the Federal Register. This means that the clock has begun ticking on the 60-day comment period, and the opportunity to influence the decision makers will end on May 6. It is critical that physicians speak up, particularly now that some will be able to respond from the perspective of their experiences in—or familiarity with—Stage 1.

In upcoming posts (after we have had the time to read, re-read, and analyze the lengthy Proposed Rule), I will discuss specific measures that I believe require modification due to their limited practicality and/or potentially adverse impact on physician workflows. Today I want to provide some high-level observations drawn from an initial evaluation of the Rule and highlight a few major implications that immediately come to mind:

  • The bar has definitely been raised! The emphasis on interoperability, patient engagement, and more extensive quality measure reporting impose very demanding requirements that represent a huge step up in capability and effort. The term “more stringent”—which is used in the ARRA legislation to characterize successive stages of meaningful use—does not begin to describe the relative intensity of Stage 2.
  • Expectations are very high, despite the fact that a vast number of physicians have not even begun to participate in Stage 1. Although CMS claims that the number of core and menu measures remains steady at a total of 20 (through some sleight-of-hand counting magic!), the actual requirements have expanded in number, complexity, and depth.
  • The proposed leap forward in the exchange of clinical data is monumental in scope. Although this is an important long-term program goal, it must be reconsidered in light of the dismal experience in this area in Stage 1. The requirement to simply test the ability to exchange clinical data met with such confusion and failure that the measure has been retroactively eliminated for 2013—the second year of Stage 1.
  • Patient engagement is another area of focus in Stage 2. Again, this is a noble goal, and physicians should be rewarded for doing everything possible to encourage patient and family involvement in care. The Proposed Rule, however, defines meaningful use to include specific patient actions, such as e-mailing their physician and accessing their information on a portal. It is unacceptable to make a provider’s incentive payment dependent upon actions by patients over which he or she has no ultimate control.
  • The Rule proposes some appealing options for streamlining clinical quality measure (CQM) reporting and harmonizing the various CMS programs that involve CQMs. However, the number of measures has exploded, and the administrative aspects of the various options will be very difficult for providers to discern.

Those are my first impressions. I will follow up with more information on these and other issues and on the procedure for submitting comments to CMS. In the meantime, I am interested in hearing your thoughts and/or concerns about the Proposed Rule and how it could impact your practice.

MGMA Confirms Productivity Loss with Government’s EMR Program

What struck me at last week’s annual meeting of HIMSS (Health Information and Management Systems Society) was the conspicuous absence of conversation about the effect of the ARRA legislation on physician productivity—there was hardly a mention of the subject throughout the conference. Jeffrey Belden, M.D., of the HIMSS Usability Taskforce, did point out that documenting patient exams in an EMR takes 10 times as long as documenting by dictation, but offered no solution to that problem. Admittedly, the audience contained few, if any, physicians. However, once again, it struck me that physician productivity was the elephant in the room—the topic that no one was discussing, even though physicians are the very people upon whom the success of the program is so dependent.

I arrived home to the release of the results of a new MGMA study (conducted last month), which concluded that practices expect that the operational changes required to meet the proposed meaningful use criteria will cause a significant decrease in productivity. Nearly 68% of the respondents anticipate such a decrease, with 31% projecting that the decrease would exceed 10%—and this was likely based on only the impact of Stage 1 meaningful use criteria.

This productivity loss is what I described in last week’s EMR Straight Talk post, where ARRA meaningful use requirements compound the reduction in productivity that is already associated with the “point-and-click” EMRs themselves. Before ARRA, physicians estimated that traditional EMRs reduced their productivity by between 20% and 40%, as documented in testimonials posted on the Government’s FACA blog and included in the Voice of the Physician Petition. Others are speaking out about this issue as well; Paul Roemer reported that his cardiologist puts the productivity loss at 30%, due to the amount of time that he “wastes” performing clerical—i.e., data entry—tasks. (Read his comments in “Healthcare IT, How Good is Your Strategy: A Scathing Rebuke of EHR.”) Added together, this means that physicians face a 40% reduction in productivity at the outset. Imagine what will happen to productivity when the more stringent Stage 2 and 3 meaningful use criteria are implemented!

The conclusion is clear. Physicians should not be considering EHR adoption for the incentive money; they should be looking at what will help them address their business and patient-care needs. The HIMSS keynote address by chairman Barry Chaiken, M.D., charged the EMR industry with “creating healthcare IT solutions that are so compelling, so irresistible, that people just want to use them.” Systems like that already exist—they just don’t interest the government, which appears to be more interested in data collection than EHR adoption.