How Much More Evidence Does CMS Need?

I was glad to see that CMS was concerned enough about the 17% meaningful use dropout rate to do some research into this rather alarming statistic. Some of what they discovered lends credence to the arguments put forth in the large—and growing—number of recent letters from stakeholder organizations suggesting that the meaningful use train is simply moving too fast.

In a recent presentation, CMS accounted for half of the non-returning providers as follows: 5% retired, 17% switched to a practice without an EHR, and 28% claimed to have simply forgotten or missed the deadline to attest.

The remaining 50% of the non-returners cited a number of reasons—some identifying more than one—that are quite revealing and can only lead to future falloffs in participation. The reasons given are presented in the CMS chart below:

How Much More Evidence Does CMS Need?

What more evidence do we need that physicians simply find meaningful use too complex, too time-consuming, and too costly? And that is only their assessment of Stage 1. Many of the non-returners were unable to meet one or more Stage 1 objectives, yet many Stage 2 measures will be considerably more challenging—for reasons other than increased thresholds. The Stage 1 menu measures that had the highest exclusion or deferral rates—i.e., the measures that most physicians did not select because they considered them to be most difficult—become required core measures in Stage 2. Compounding that challenge is the addition of totally new measures related to interoperability and patient engagement, all of which will require completely new workflows, staff training, and massive patient-education efforts.

Given the experience to date, the associated explanations provided by physicians, and the volume and passion of the requests pleading for some relief—from the burden of the requirements and from the impending penalties—some flexibility is clearly called for. How about at least backing off from the all-or-nothing requirement? Doesn’t it make sense for the long-term success of the EHR Incentive Program to offer physicians some flexibility at this critical juncture?