Test Your Meaningful Use IQ – Stage 2 and 2014

Meaningful Use Stage 2 IQ TestFor many physicians pursuing the EHR incentives, 2014 means moving on to Stage 2 of meaningful use. Stage 2 is much more complex than Stage 1, with higher thresholds for most Stage 1 measures; core (i.e., mandatory) requirements that were formerly menu (i.e., optional); and totally new measures related to interoperability and patient engagement that will require revised workflows. It’s not too early to start learning about Stage 2, and I would suggest that physicians and their staff members take advantage of the abundant educational opportunities that already exist. CMS has produced helpful tipsheets and guides for providers, and you should expect your EHR vendor to offer comprehensive training programs on Stage 2. Another good way to learn about the new requirements is to attend a webinar—there are many, and I invite you to attend one of my company’s webinars that will prepare you well for 2014.

In the meantime, test your basic knowledge of 2014 and Stage 2 by taking this quiz. If you have any questions of your own, please comment below and I will be happy to respond.

Meaningful Use Breathing Room Appears on the Horizon

Meaningful Use Breathing Room Appears on the HorizonAmid the abundant (and yet unanswered) pleas from all quarters to extend or delay Stage 2 comes some potential good news about the scheduling of Stage 3: It’s becoming clearer and clearer that Stage 3 won’t start for anyone before 2017—at the earliest.

Although I have not seen any formal announcements by CMS or ONC confirming this, a recent legislative update from the EHRA (the HIMSS EHR vendor association) reported that the proposed rule on Stage 3 is not expected until late 2014. There are many steps and a defined timeline that transpire between the release of a proposed rule and implementation of the final regulations in the field. First, there is a 90-day comment period, during which all stakeholders have the opportunity to express their support and/or concerns about every aspect of the proposed rule. Then, the government needs another 90 days or so to consider each comment and create the final rule, in which it responds to these comments. That takes us to mid-2015. To give the EHR vendors anything short of 18 months to complete product development, test usability, deploy their upgraded software, and train their clients would meet with overwhelming resistance. Implementation of Stage 3 before 2017 would be highly unlikely.

This breathing room is a good thing for physicians. As I have discussed in prior EMR Straight Talk blogs, meaningful use has essentially stifled innovation by driving EHR vendors to focus the lion’s share of their development efforts on government requirements. Now physicians will benefit from the vendors’ ability to deliver the innovative workflow enhancements that providers need, and they will have time to hone their workflows to more efficiently meet the government’s requirements.

The Metastasizing Complexity of Templated Exam Notes

The Metastasizing ComplexityThe problems associated with templated exam notes have been well documented. From the amount of time it takes to build the notes by entering every piece of data via pointing and clicking, to the sheer length of the output that makes it hard for physicians to find the information they need, to the challenges related to upcoding and cloning (factors that the government is actively investigating), templated notes have been tolerated as a necessary evil associated with EHRs. But there are better ways to capture, exchange, and analyze discrete clinical data with precision, and without adversely affecting physician productivity.

As government programs rapidly evolve, and the number of such programs increases, the need to capture and analyze data will change and grow—think: new stages of meaningful use, PQRS, and the impending switch to ICD-10. An interview with orthopaedic surgeon Scott W. Trenhaile, M.D. in AAOS Now illustrates the increasing template-related burdens associated with ICD-10, just as an example. “We’ve spent a considerable amount of time on templating and are adjusting our templates to address those issues. . . . We’re changing the EMR templates to ensure that ICD-10 issues are covered. Answering certain questions in certain ways opens other templates so we have the information needed for ICD-10 coding.”

Just this past week, the number of anti-template commentaries published in the media has exploded.

  • The problem was aptly described as “note bloat” in a recent presentation to attendees of CHIME’s CIO forum, where the problems associated with typical EHR documentation of a patient exam were lamented.
  • A recent survey conducted by the American Medical Association and reported by the RAND Corporation cited the prominent concern among physicians that EHR technology “requires physicians to spend too much time performing clerical work and degrades the accuracy of medical records by encouraging template-generated notes.”
  • Bill Cayley, Jr., M.D., a family-medicine physician, blogged, “With the increasing use of electronic medical records (EMRs) and their ever-so-helpful templates, smart sets, and forms for capturing information needed to support billing and guide protocols, I fear we are losing the narrative forest for the well-documented trees.” He goes on to say, “Far too often, doctors are being forced to re-gather the entire history with the patient themselves, because prior documentation fails to provide the nuance needed to understand what happened during the last visit.”

If physicians are struggling with templated notes now, their problems are bound to be exacerbated as EHRs layer more and more levels of complexity onto already bloated platforms to try to keep up with the government’s voracious appetite for data.

Physicians need nimble and flexible data platforms to support the data-capture needed to identify and reward quality of care while maintaining physician productivity. The metastasizing complexity of the templated exam note can only lead to its demise.

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?

17% Meaningful Use Dropout Rate—Just the Tip of the Iceberg

17% Meaningful Use Dropout Rate—Just the Tip of the Iceberg

My last EMR Straight Talk post, which addressed the alarming 17% meaningful use dropout rate, generated many comments and resulted in several subsequent media interviews. While CMS has acknowledged the facts regarding this program failure, it does not acknowledge the gravity of the implications for the future of the program. According to a Bloomberg News article, CMS attributes the fallout to many of the same reasons that I have identified from the outset—program complexity, lack of fit with specialty practices, cost, dissatisfaction with EHRs, and inability to meet the meaningful use requirements.

To evaluate the program’s future, it is necessary to understand why physicians participate in meaningful use to begin with, and what their motivation would be to continue to participate once they have purchased a certified EHR and recouped $18,000 of its cost. A simple financial analysis begs the question: Why would physicians do dramatically more work for significantly less money?

One only has to look at the math to predict the future. As the table below illustrates, the financial value of the incentives drops by a factor of 10 at the same time that the program requirements increase precipitously. If 17% of physicians abandoned the program when the incentives fell from $6,000 to $1,000 per month of meaningful use effort, what should we realistically expect to happen when the incentives drop even further and the complexity increases?

Total $ Value of Participating in the EHR Incentive Program

*Estimate based on annual Medicare revenue of $300,000. Penalty = 1% in 2015, 2% in 2016

I am certainly not saying that physicians are only motivated by money—of course they want to do the right thing and provide the best possible care for their patients. And shunning meaningful use does not preclude them from leveraging their certified EHRs to exchange clinical data with other providers. But physicians have been quite outspoken about their concerns from the beginning, expressing their perception of the program as overly burdensome, wasteful, and distracting from their mission to provide that care. Now, the evidence is in—they are not just speaking, but they are walking. Clearly, to ensure the ongoing success of meaningful use, the government must fundamentally reduce the program’s complexity.

Alarming Fact: Meaningful Use Dropout Rate at a Staggering 17%

Alarming Fact: Meaningful Use Dropout Rate at a Staggering 17%Here’s an alarming fact: the meaningful use dropout rate is already 17%.

A recently published assessment of the government’s April EHR attestation data revealed that 17% of the providers who earned an $18,000 EHR incentive in 2011 did not earn the $12,000 second incentive in 2012. Although the analysis was performed by the venerable Wells Fargo, my immediate response was, “That’s impossible! They must have miscalculated the data.”

So I crunched the numbers for myself, and to my astonishment, the conclusion is absolutely correct. A staggering 17% of the providers who succeeded at demonstrating meaningful use for 90 days were unable to sustain that performance for a full year—the second required reporting period—despite the fact that the program’s requirements remained exactly the same and the providers already had the necessary workflows in place to support those requirements. What makes this fact even more troubling is that the 2011 attesters were typically the early EHR adopters and therefore most experienced in the use of the technology.

A 17% loss rate in any business is wholly unacceptable, and this failure does not portend well for the future of the EHR Incentive Program. If $12,000 proved to be insufficient motivation for physicians with meaningful use experience to meet the relatively low requirements of Stage 1 on an ongoing basis, it would be foolish to expect physicians to muster the wherewithal to meet the increasingly demanding requirements of Stage 2. The incentive for a year’s performance at that point will be a mere $4,000.

Compounding this finding is the fact that 14% of physicians who attested to Stage 1 have already stated that they have no intention of attesting to Stage 2, according to another recent survey. And we can be sure that this number will rise as physicians begin to familiarize themselves with the labyrinthine requirements. If physicians are not motivated by the remaining incentives, it’s equally clear that the imposition of penalties for noncompliance will yield no better results. There is already a groundswell of objections to the penalties, including a bill introduced in the House seeking numerous exemptions, letters from AMA and AHA, etc.

So, is this the beginning of the end of meaningful use? What is keeping physicians from continuing to participate in the program? Are they bailing or failing? In either case, it is just too complicated—physicians are demonstrating that they are not willing to divert their attention from treating patients to consistently devoting the time necessary to keep track of the myriad measures on which they must successfully report. Instead of making meaningful use increasingly complex, we need to simplify it—focus on interoperability and leave the physicians and their clinical staffs to practice medicine. If we do not, the entire program will go down the drain. Let’s not throw the baby out with the bathwater!

Physicians Spooked by Failure Stories—EHR Adoption Suffers

Physicians Spooked by Failure StoriesA significant portion of the physician market has still not adopted an EHR, despite the lure of government incentives and the fear of the penalties looming on the horizon. The stock prices of most publicly traded ambulatory EHR companies are down sharply, as sales are lower and earnings projections have not been met throughout the industry. How can this be, when the EHR incentive program has successfully increased EHR adoption and was expected to be such a boon to EHR vendors?

I know why, and it is not—as commonly thought—because the initial EHR-adoption rush fostered by the incentives has ended. Rather, it is because of rampant physician dissatisfaction that has reached a more-than-palpable level. I have noticed a dramatic change in the tenor of conversations with physicians, most recently at professional society conferences, where physicians who have not yet purchased an EHR are frozen in their tracks. They are worried by the horror stories they hear from colleagues—even from those who have succeeded at meaningful use—because many of those physicians continue to experience major workflow disruptions and significant productivity losses from which they see no potential to rebound. Recent surveys point to the number of physicians looking to replace their EHRs, and based on my company’s experience in the replacement market, that number is growing. A recent article summarized the findings of a large study on EHR satisfaction and presented an insightful analysis of the potential reasons for these disappointing results.

This heightened level of frustration has resulted from frantic, insufficiently researched EHR purchase decisions by physicians and rushed, inadequate implementations conducted by resource-strapped vendors. Massive EHR failures are exactly what I predicted in an EMR Straight Talk post on the unintended consequences of the EHR incentive program in February 2010:

After an initial peak in implementations, long-term EHR adoption will slow—particularly among high-performance specialists—and the current failure rate will escalate. Many factors will contribute to this: (1) Some physicians will rush into EHR purchases without conducting proper due diligence. (2) Products that were overly complex and did not work in busy specialists’ practices in the past will surely not succeed now, particularly since these same products must now be used in an even more structured and demanding way. (3) Sorely needed implementation and training will be provided by inexperienced and rushed implementation teams, further reducing the likelihood of success with providers, many of whom are less technologically savvy than the early adopters. (4) Where there was never a convincing economic justification in the past, the addition of data-collection requirements will further lessen the economic feasibility of traditional, point-and-click EHRs. . . . The result? The high failure rate will leave physicians “holding the bag” after investing large sums of money, failing to earn the anticipated incentives, and owning a system that doesn’t meet their needs.

So, what can physicians do to avoid falling victim to EHR failure, and to instead reap the benefits of successful EHR adoption—government incentives and practice productivity? I have written extensively about the importance of physicians doing thorough and objective reference checking—that advice is as valid now as when I first wrote about it, and perhaps is even more critical today. For guidance on how to conduct a thorough and fair evaluation of an EHR, read EMR Selection: How to Uncover the Truth or 100% EHR Success – A Clinical Approach.