D'Arcy Gue

Is Slow Progress Towards Stage 2 Attestation Reason for Concern?

May 8, 2014

Meaningful Use / MIPS 3 Minute Read

Elisabeth Myers, a senior official at the CMS’ Office of eHealth Standards and Services, told the CMS Health Information Technology Policy Committee that four hospitals have attested to Stage 2 Meaningful Use / MIPS so far this fiscal year. Initial reaction to this information seems negative, adding fuel to the fire of providers requesting a delay in the Stage 2 implementation date, or perhaps a shortening of the measurement period to 90 days, which would allow providers nine more months to begin measuring Stage 2 compliance without formally moving the deadline. Is that reaction justified?

Hospitals have four quarterly chances in this fiscal year to measure their usage data to prove Meaningful Use / MIPS. At this stage two of the four quarters have passed, with only four of the 30 hospitals that have attested so far attesting to Stage 2 (13 percent).  The immediate reaction – that four hospitals out of over 5,000 is extremely bad — is misguided. To be required to attest to Stage 2 this year, a hospital would have had to attest for the first time in FY2011, and only 16 percent of hospitals did.  Based on this, we can expect 16 percent of hospitals to attest to Stage 2 this year. With that baseline, to see that 13 percent of attesters have met this challenging goal in the first half of the year is actually quite encouraging.

When asked directly if the Stage 2 attestation numbers were an indication of success (or failure) of the Stage 2 program, Myers said, “We don’t have enough data.”  Based on the numbers provided, her assertion is most certainly correct.

Also worthy of comment is that only 30 eligible hospitals have attested this year. Out of the total population of hospitals, that number is well under 1 percent of the total hospitals. Given that 84 percent of hospitals did not attest for the first time in 2011, and only 5 percent have yet to attest, one might wonder why so few have attested to Stage 1 this year. The reason, based on my own observations with client hospitals, is that hospitals and vendors are both challenged to implement two new (and significant) technologies in 2014

  1. View/Download/Transmit – a requirement for a patient portal
  2. Electronic Clinical Quality Measures – a requirement that quality measures be calculated using specific methods and directly from the EMR, not from separately abstracted data.

This observation is supported with data released by Jennifer King, the acting director of the Office of the National Coordinator for Health IT’s Office of Economic Analysis, Evaluation, and Modeling.  She noted in her presentation to the HIT Policy committee that “many of the Stage 2 Meaningful Use / MIPS functionalities had very high adoption rates,” but noted that others are lagging behind. Only 10 percent of hospitals reported having EHR systems that could meet the “view, download and transmit” objectives.

There is Partial Relief

In response to hospitals whose vendor issues cause implementation challenges, CMS has added a new category – 2014 EHR Vendor Issues – to their Hardship exceptions. This exception is specifically for hospitals whose inability to attain Meaningful Use / MIPS during the 2014 program year was due to cases where “The hospital’s EHR vendor was unable to obtain 2014 certification or the hospital was unable to implement Meaningful Use / MIPS due to 2014 EHR certification delays.” These hardship exemptions won’t allow a hospital to receive Meaningful Use / MIPS incentive funding,  but they do allow hospitals to avoid significant Medicare payment reductions.

One thing the numbers indicate clearly is that Meaningful Use / MIPS attestation in 2014 is a challenge. There are a number of strategies providers can employ to address these challenges and make the attestation process less daunting. We have been working with our clients to address these issues and have significant experience in Meaningful Use / MIPS attestation. If you are looking for assistance, contact us!

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