CMS tried to bury it with a late press release on a Friday afternoon, but their proposed extension of Meaningful Use Stage 2 is already making waves. Initially it seems there was quite a bit of confusion about “delaying Stage 2” when the start date doesn’t change. For those of you who haven’t read the actual CMS release (the site was unresponsive most of the times I tried today), the key point is that Stage 2 will be extended through 2016 and Stage 3 will begin in 2017 for those providers that have completed at least two years in Stage 2.
Clear as mud? I thought so. CMS claims the change will allow it to focus on successful implementation of the Stage 2 requirements and also to allow it to use Stage 2 data to “inform policy decisions for Stage 3.” What does this mean for those of us in the trenches, particularly small practices? Is Stage 2 going to be a “best two out of three” where if you miss in one of the years, you can use a mulligan? Are they going to use the data to see that people are failing and make Stage 3 more realistic? Will they see that people are opting out by abandoning Medicare and make some changes? I doubt it.
If CMS really wanted to make a difference for rank and file providers (keeping in mind that not everyone is employed by a hospital, health system, or large medical group) it would remove the need for Eligible Providers to meet every requirement in an all-or-nothing fashion. Our hospital has an entire team of people devoted to keeping up with CMS and reading all the FAQs. The team subsequently educates the employed physicians. I can’t even fathom what it would be like to be in a solo practice or a small group and to try to keep up with it all.
The release summarized the goals of Meaningful Use. It’s been a long time since I read the initial announcements and documentation from CMS and maybe in trying to keep up with all the details I had forgotten what they were. Seeing them again struck me a little funny: “The phased approach to program participation helps providers move from creating information in Stage 1, to exchanging health information in Stage 2, to focusing on improved outcomes in Stage 3. This approach has allowed us to support an aggressive yet smart transition for providers.”
Really? Aggressive yet smart? In my experience as a CMIO having to coach my peers through this, it hasn’t seemed very smart. Although we’re certainly creating a lot of information, it doesn’t feel like most physicians are using it to do anything other than check the boxes for the Meaningful Use requirements. Why couldn’t we have followed Stage 1 with an outcomes stage directly related to the data collected initially? Exchanging information is important, especially for patients who see multiple physicians and receive care in multiple environments, but putting too much focus on it seems a bit like putting the cart before the horse.
In Stage 1, providers are busy clicking boxes about tobacco use, gathering structured ethnicity and race data, and essentially doing nothing with it. I’m not seeing many of my peers using that information to better their attempts to help their patients stop smoking let alone to create or improve population-based interventions based on the makeup of their patient panels even though they now have that data. Physicians feel like they’re on a hamster wheel with no way off and are not making the connection with how the data will be helpful in the future.
In putting outcomes last, CMS shows they’re focused on large-scale outcomes rather than the micro-type outcomes that lead to better health for individuals. In looking at how public health has tackled population-based problems in the past, we’ve seen that it can take decades to move the needle where national health issues are concerned and sometimes we aren’t moving it anywhere near enough, such as with obesity.. Most of my physician colleagues are focused more on individual outcomes and work to do their best for every patient each time he or she is seen rather than worrying about everyone out there.
It’s challenging to get them to think about populations when they’re trying to figure out how to get the patient in front of them enrolled in multiple pharmaceutical company patient assistance programs, how to arrange transportation to other appointments, how to order tests and referrals, and how to address multiple mental health issues all in a 10- to 15-minute appointment. Additionally, let’s not forget trying to get all these services pre-authorized and pre-approved because insurance companies try to block them even though they’re medically necessary. And they’re also doing it while trying to see enough patient volume to pay for employees to handle all of the above so they can actually care for patients.
Hindsight is 20/20, but it seems like it would have made more sense to put in place strategies for physicians to see how gathering discrete data can be of benefit and use those experiences to encourage people to continue through the Meaningful Use program. For those of us in groups that were ahead of the game and have been gathering that data and using it for years, how about bonuses for moving more quickly through the program?
In the announcement CMS also notes that this timeline shift will allow “more consideration of potential Stage 3 requirements [and] additional time for preparation for enhanced Stage 3 requirements.” Any Eligible Providers who don’t think this is an opportunity to make Meaningful Use even more arduous and complicated than it already is should rethink their impressions of the program. There are some providers out there who actually think this is just a three-act play. I would be shocked if Stage 3 is the end.
CMS plans to release a Notice of Proposed Rulemaking for Stage 3 in the fall of 2014 along with the 2017 Edition of the ONC Standards and Certification Criteria. The final rule is to be released in the first half of 2015 which still only gives providers and hospitals (not to mention vendors) about a year and a half to be fully compliant. That certainly doesn’t feel like we’re coming off the treadmill as much as most of us would like.
Organizations such as CHIME have already come out stating that the timeline shift doesn’t change the fact that Stage 2 and ICD-10 are going to hit at the same time in a “perfect storm.” CHIME is pushing for flexibility in the start date of Stage 2. HIMSS is supportive of the extension but continues to ask that the first year of Stage 2 allow at least 18 months for attestation.
I did find one bit of silver lining in the announcement, and that is the voluntary nature of the 2015 Edition of certification criteria. The release specifically states that providers will not be required to upgrade to a 2015 Edition EHR and vendors who have certified to the 2014 Edition would not need to recertify. Since I’m already on a certified version that’s ready for Stage 2, it is a relief to not have to take another major regulatory upgrade for a while. Instead we can focus on updates that bring actual clinical functionality to help our patients which unfortunately feels like a novel concept, assuming our vendor is able to get back to the development plans they had before Meaningful Use reared its sometimes-ugly head.
The devil will be in the details, but I’m not going to lose sleep waiting to find out what they are. I strongly suspect our hospital will elect to continue on our current trajectory (minus the anticipated Stage 3 payments for 2016.) Unless CMS pulls a rabbit out of its hat, we’ll be OK. What do you think about the proposed changes to the MU timeline? Email me.
Email Dr. Jayne.