EHR Incentive Program Financed on the Backs of Physicians

I was shocked to read the following paragraph, buried on page 379 of the 455-page Proposed Rule for Stage 2 Meaningful Use, (page 13812 in the Federal Register). The paragraph also appears verbatim in the Final Rule for Stage 1:

Explanation of Benefits and Savings Calculations:

In our analysis, we assume that benefits to the [EHR Incentive] program would accrue in the form of savings to Medicare, through the Medicare EP payment adjustments [penalties]. Expected qualitative benefits, such as improved quality of care, better health outcomes, and the like, are unable to be quantified at this time.

While the second sentence is disappointing, I do respect CMS’s candor in acknowledging the ongoing paucity of hard data on the quantification of the assumed qualitative benefits of EHR adoption. The first sentence, however, left me short of breath because it points to the following inescapable, disheartening conclusion: The economics of the EHR Incentive Program is predicated upon physician failure!

EHR Incentive Program Financed on the Backs of Physicians

In fact, the government’s projections for physician participation from 2014 through 2019 are rather pessimistic. Meaningful use among Medicare EPs is estimated to grow, in the less optimistic (“low”) scenario, from 18% to a mere 36%, and in the most optimistic (“high”) scenario, only from 49% to 70%.¹ Even these high projections are low enough—incidentally—to give the Secretary of HHS the option to increase the penalties from the statutory 3% in 2017 to a potential 4% in 2018 and 5% in 2019.

What kind of program have we created that over a period of 9 years will likely take almost as much money from physicians as it gives them?

The government giveth and the government taketh away!

¹Source: Proposed Rule, Stage 2 Meaningful Use, page 13804, Table 19.