The proposed rule for meaningful use Stage 3 was announced on Friday, March 20, 2015, and is now available for comment by stakeholders. Here are five highlights of the Stage 3 proposed rule and what I see as three provider wins:
Highlights
2017 is now a Flex Year– Meaningful use Stage 3 was originally slated to begin in 2017 for providers that had completed Stage 2; now 2017 is a flex year. This means that providers who would have progressed from Stage 2 to Stage 3 in 2017 now have the option to stay in Stage 2 an additional year. Only providers who use an EHR certified to the 2015 ONC standards will be allowed to attest to Stage 3.
Every provider will be Meaningful Use Stage 3 in 2018 even if 2018 is the provider’s first reporting year – In order to simplify the meaningful use program, all providers will be in the same stage. This will allow group practices to focus on a single set of measures for all providers.
Meaningful Use Stage 3 is the final stage of meaningful use– However, CMS is clear that because it expects technology and care standards to evolve over time it will consider (and we expect) that there will be future rulemaking related to meaningful use Stage 3 somewhere down the line.
All providers will report for one calendar year – in an effort to continue to align meaningful use with other government reporting programs such as PQRS, all providers will report for a full year based on the calendar with one exception. Medicaid first year providers will still be allowed to report based on a 90-day period measurement period. In the past CMS has shortened measurement periods based on provider feedback and we expect that to be true about this year. This year (2015) was slated to be a full year for most providers, but we expect it to be scaled back to a quarterly measurement period because of the continued side effects of the poor implementation of Stage 2 last year. For 2017 and beyond, we expect the implementation will be smoother and we don’t foresee more flexibility on measurement periods beginning next year.
There are eight objectives and some objectives have more than one measure – the total number of measures that providers will be required to report is 16.
Wins for Providers in the Meaningful Use Stage 2 Proposed Rule
I see three wins for providers in the meaningful use Stage 3 Rule, including:
Robert Hitchcock, M.D., FACEP, is T-System’s vice president and CMIO, leading the company efforts for solving regulatory issues and identifying trends. He is a nationally recognized meaningful use expert and active member of the HIMSS Physician Committee and other HIMSS subcommittees advocating usability and responding to regulatory issues.
Dr. Hitchcock also is a practicing ED physician and an Emergency Department Practice Management Association (EDPMA) board member. In 2001, he earned recognition for excellence in teaching from internal medicine residents, and in the early 2000s, he trained basic and advanced life-support EMS providers. His goal is to advance system adoption and usability to improve the quality and efficiency of ED delivery.
Here, he provides perspective about developments of meaningful use Stage 2 and Stage, how meaningful use is impacting vendors and practices, how they feel — or should feel — about it, and what Stage 3 means for everyone in the industry.
How do you see the market responding to meaningful use? How are physicians moving forward, or beyond, it?
The market’s overall response to meaningful use is generally clear: they’re pushing back, particularly on Stage 2. Vendors aren’t ready, so there are not as many certified products out there. Physicians and hospitals are both calling for delays. By some estimates, as many as 50 to 70 percent of physicians who were successful in Stage 1 will not be successful in Stage 2.
To give some perspective, the Eisenhower interstate system was authorized and construction began in 1956. Phase 1 was completed in 1992. It took 35 years to build roads in this country, a decidedly low-tech undertaking. With meaningful use, we’re attempting to take a relatively un-automated industry and automate it beyond what was ever considered possible in six years. Everyone is pushing back because it’s simply too much, too fast.
Along with HIMSS’ largest money maker of the year — its annual conference — it’s also time for the results of its annual leadership survey.
While the results, which are reflected in the infographic below, are certainly interesting there is one point that seems to raise a flag immediately.
Prior to that, however, let’s take a quick look at the results. Accordingly, about 66 percent of the all health IT leaders say their organization qualified for meaningful use Stage 1 and 75 percent of the same folks expect to qualify for Stage 2. Additionally, nearly 90 percent of those who took the survey say they be ready for the ICD-10 switch later this year.
As such, there’s quite a need to hire new IT folks to carry the torch.
Next, it appears that nearly 20 percent of respondents said their health systems’ security was breech (at least those who admitted as much) and that 22 percent of said security was a priority for the coming year, which should be the case if 20 percent of them faced a security issue.
I understand the scope of the survey and who its respondents are, but doesn’t it strike anyone else as slightly odd that all of the changes to come are related to the IT? All, or much, of the reform is designed to engage patients and bring them closer to their care providers? Shouldn’t it be implemented to help improve outcomes and to drive better results and make the system more fluid? I guess IT is going to be what get’s us there. But along the way, couldn’t more be done at the care level as well as the IT level? Could some of the hiring take place to serve patients rather than the practice?
I digress. Apparently, for now, we’ll have to be thankful that all of this change is leading to improved job growth and fixes to the breeches that await us.
Guest post by Chris Giancola, principal consultant at CSC.
Looking into what’s ahead, 2013 will be another year of compliance activities dominating the healthcare landscape. Mandates on the industry, from both the ARRA and ACA, are fully underway and stretching the financial and intellectual resources of healthcare providers and insurers across the country. Here are three major compliance pressures facing the industry this year:
ICD-10 – Though the U.S. Office of Health and Human Services delayed the ICD-10 compliance deadline to October 2014, it did so back in August 2012. This early action by HHS acknowledges the enormous scope of the challenge facing providers, HIT vendors and insurers that stands to impact every administrative process and workflow. Far beyond simply recoding claims, any process involving a diagnosis will materially change because of the higher degree of clinical specificity described by the ICD-10 code set, such as obtaining referrals and lab tests for patients, providing clinical decision support and e-prescribing.
Insurers and providers also will face the challenge of understanding how the code changes may impact their bottom line by determining the financial neutrality of any potential change in diagnoses and payment for treatment of those conditions. Providers relying on vendors with fixed or appointment-style upgrade schedules should consider as early adoption as possible to reduce the potential negative impact of these changes. There also will also be a period of overlap where both ICD-9 and ICD-10 code sets will need to be supported by all participants involved, increasing the complexity of the problems looming on the horizon.
Organizations that are late on their remediation timelines will increasingly look for solutions, like selective outsourcing and alternative technical solutions that will allow them to minimize the implementation risk and operating costs of achieving necessary compliance. But, if the ANSI X12 4010 to 5010 conversion was any indicator, these alternative solutions will be offered at a premium price.
Meaningful Use Stage 2 – Stage 2 makes much of the optional menu set of objectives in Stage 1 a part of the mandatory core set, meaning that those providers who deferred as many of the optional objectives as possible now face challenges in Stage 2 they can no longer avoid. Also, in 2014, penalties for noncompliance with Stage 2 will begin to take effect, and so 2013 will be the year for many providers to buy or build new capabilities, such as web-based and device-accessible portals to satisfy patient engagement objectives and to change clinical workflows to meet Stage 2’s objectives and gather new mandated quality measures.
In Stage 2, Eligible Physicians (EPs) must complete 17 core and three of six menu objectives for a total of 20 objectives. Eligible Hospitals (EHs) and Critical Access Hospitals (CAHs) must complete 16 core and three of six menu objectives for a total of 19 objectives. Though Medicare or Medicaid incentive payments will offset some of the financial impact of implementing electronic health records, the impact to administrative and clinical staff, as well as to previously paper-based workflows, will be nontrivial.
Payment Reform – Many providers have already felt the financial impact of changes to their contracts with insurers that are implementing alternatives to the fee-for-service reimbursement models of the past. Bundled payments to providers for disease-state management will require higher degrees of care coordination and information sharing not only within delivery systems but across disparate organizations and affiliations.
Effectively managing referral networks will be a key success factor in the coming year. New payment contracts also typically require greater degrees of reporting to the insurer to ensure that quality of care is not being compromised, further increasing the burden on providers to gather, harmonize and report on clinical data previously written on paper or buried in unstructured text.
Compliance with these mandates, though not imposed by federal or state regulations, will grow to be a larger challenge as these new payment models mature and they represent a larger portion of providers’ revenue streams.
Chris Giancola is a principal consultant at technology consulting company CSC with a combination of technical skills, project and product management experience, business development successes, and healthcare domain expertise.
To this point in the meaningful use experiment, Phil Suiter, CEO of digiChart, has had the privilege of sitting at the front of one of healthcare’s greatest movements. From his place, he’s watched the market act and react, and has seen colleagues seek solutions to corner their respective markets all in the name of providing the best service for the most people.
Suiter, however, may have a view of the current health IT landscape like no other. Leading a specialty only provider of electronic health records and practice management systems, digiChart serves only OBGYNs.
Long before healthcare reform and the thought of meaningful use, digiChart created and built solutions solely for this space, and, unaplogoetically, will continue to serve the space. Plans for expansion may one day include moving into the pediatrician market, which seems to be a safe bet given the connection between the two specialties, but according to Suiter, that’s not a plan actively being pursued.
What’s interesting about digiChart’s position, as Suiter tells it, is that even though meaningful use is vitally important to digiChart and the company has helped many physician achieve stage 1, OBGYNs have not voraciously jumped aboard the program.
What this means, he says, is that it’s a clear sign that the OBGYN market continues to live up to its reputation as a fiercely independent group of healthcare providers. Suiter said that only 20 percent of all digiChart’s clients have chosen to pursue meaningful use. Apparently, the other 80 percent have chosen to overlook the federal incentives and go at it alone.
From conversations he’s had with clients, they’re just are not seeing the benefit of meaningful use, especially for all of the work required with the only benefit is $44,000 over five years.
“At this particular point, they don’t realistically see a flip side in changing. In some practices, some have decided that they are better off without changing,” Suiter said. “Practices have determined that they can survive and be profitable if they are efficient and continue doing what they are doing, especially in the OBGYN space.”
Being profitable means they’ll ultimately forego Medicare patients to avoid the federal penalties levied against them for not meeting meaningful use. In many cases, they don’t see enough Medicare and Medicaid patients to make all the effort worth their while, Suiter said, so the work required simply is not worth the effort.
And, frankly, the question remains: Is the federal money going to still be available as stage 2 progresses? And, what happens in February 2013, should a new administration take office?
Despite the answers to these questions and whatever happens with the election in November, Suiter sees plenty of change ahead for the market. For example, EHR vendor contraction is coming after a period of great anticipation.
He predicts the market will dramatically shrink from more than 400 companies to less than 100, many fewer of them actually viable and sustainable long term.
At the same time, he believes hospital’s appetite for buying and owning private practices will disintegrate as soon as 12 months from now.
“I think we’ll see a disgorgement of practices by hospital systems within the next 12 to 18 months,” Suiter said, marking the end of a repeat performance last seen in the mid-1990s (1995, ’96 and ’97, he said specifically).
Hospitals have been voraciously trying to align themselves with private practice to capitalize on funds generated from meaningful use; however, they don’t seem capable of effectively managing private practices and their employees as they seem to be able to do with their internal systems and hospital employees, he said.
Private practices are too independent, for the most part, he said; especially, OBGYNs.
The fiercely independent group of physicians might have all the leverage they need to withstand outside pressure for adopting new technologies or changing the way they run there businesses at this point in their careers.
Why?
The average physician in the OBGYN space is 62 years old. At this point in their careers, they are not particularly interested in becoming hospital employees and if they are not interested pursuing meaningful use, which seems to be the case, they’ll either retire or go their own way.
Clearly, the technology used in healthcare will gain greater acceptance as new doctors enter the space. As colleges begin to implement the systems to train their residents (which they are not readily doing now), perhaps the appetite within the space will change. Clearly, there’s room for more adoption in the market Suiter serves.
But, digiChart is positioned well, serving a market it, and Suiter, understand, and know they’re place – as leaders – in it. There are very few vendors that can represent the specialty space well, especially in the land grad market of one-size-fits-all solutions penetrating the market. DigiChart and Suiter seem to understand that sometimes it’s better not to be the jack of all trades, but a master of one.
