July 9, 2013
It’s impressive. HHS has met and exceeded its early goals in the move to Meaningful Use / MIPS — 50% of physician’s offices and 80% of eligible hospitals have moved to EHRs, and have attested for Meaningful Use / MIPS Stage 1. The target date was to be the end of 2013, and here we are, just halfway through the year. According to results published at the end of April 2013, 4,371 (81%) hospitals have attested to Stage 1 Meaningful Use / MIPS and 3,880 (72%) of hospitals have received their incentive payments.
This, indeed, is good news for HHS, the healthcare environment and the hospitals that have attested.
But, this still leaves 19% of hospitals that haven’t attested to Stage 1. If hospitals didn’t begin their attestation period by July 1, they will not make it to Stage 1 in time to receive the associated incentive payments. What’s more, if these hospitals continue to delay, by 2015, they will begin to experience reductions in their Medicare payments.
The Fourth of July holiday has passed and the hospitals that haven’t started their attestation have no chance of receiving incentives for Stage 1. And there is a very long road ahead for them to achieve Stage 2. The Stage 1 requirements pale in some ways to those in Stage 2, since the latter is focused on interoperability across organizations and systems. Hospitals that are behind, have positioned themselves for a staggering amount of work to do in a limited amount of time.
We assume that many of these hospitals understand the requirements, deadlines and incentives associated with Meaningful Use / MIPS. If so, why didn’t they perform the initial work required in Stage 1 to get on track and receive the incentives?
We asked this question of ten industry leaders. We received a remarkable near-100% response within three days — everyone had an opinion. Our respondents range from HIT academic leaders to former HHS staff to healthcare IT association leaders to experienced HIT consulting executives.
This is what we heard:
There’s no incentive to move to Medicare or Medicaid.
A small, but significant, number of US hospitals don’t have a Medicare or Medicaid population, so there’s no incentive to upgrade to a certified EHR.
The incentives don’t outweigh the costs.
The move to Meaningful Use / MIPS is expensive, and there is a perception by some organizations that the cost of meeting Meaningful Use / MIPS requirements is just not worth it. The more complex and expensive the requirements are perceived to be, the less powerful the incentives are.
The hospital is too small and underfunded.
Some hospitals, especially rural critical access hospitals, don’t have the budget to even begin to move to Meaningful Use / MIPS. Some are still working primarily with paper, pen and FAX. A hospital that commits to Meaningful Use / MIPS must make an investment in EHR technology before it will receive any cost offset through incentives. This is just not possible for this group. Many of these hospitals are banking on Medicaid money.
Competing initiatives are causing hospitals to delay or opt out of Meaningful Use / MIPS.
Meaningful Use / MIPS is complex and expensive. Adding Meaningful Use / MIPS to hospital staff’s plates that are already brimming with mandates to cut costs, transition to ICD-10, update privacy and security policies and processes — and, of course, manage the the day-to-day running of the hospital — is just too much to handle.
Hospitals have been waiting — or couldn’t get it together — until the last minute.
For a hospital, Meaningful Use / MIPS requires more than just software upgrades. It requires personnel, infrastructure, and cultural changes in how they practice medicine and manage the business of healthcare. It also requires IT staff with specialized expertise, which the hospital may not have. Procrastination has been a natural response to the workload and skills required by this move.
With Meaningful Use / MIPS comes expenses. Planned budgets need to be approved, which often requires a long board-level approval process to obtain the additional IT and clinical resources, and invest in new or upgraded EHR systems.
Meaningful Use / MIPS transition also requires vision, understanding and commitment. Some key clinicians, hospital executives and board members may be missing one or all of these requirements. When implementing systems and processes that are this significant to the enterprise, these issues can slow decision-making down to a crawl.
Despite these delaying factors, we know from intelligence we received in May and June, that some hospitals have been feverishly working down to the wire to ensure they could initiate their attestation periods by July 1. We hope they have succeeded. Perhaps these late bloomers will bring the percentage of Stage 1 Meaningful Use / MIPSrs much closer to 100% by fall.
However, it’s inevitable that there are many hospitals who aren’t on this last-minute trajectory. Meaningful Use / MIPS will remain off their radar. What will it take to get those hospitals on board?
We recently have been told by CMS that 17 percent of providers who collected their 90-day Stage 1 incentive payments in 2011 have either decided not to move on to Stage 2 for the following year, or have been unable to do so.
If Meaningful Use Stage 1 doesn’t capture essentially all eligible providers, and Stage 2 remains prohibitive to a significant percentage of providers, what will this mean for the federal vision of a nation-wide, integrated healthcare environment? What will it mean for population health management, which per Farzad Mostashari, the National Coordinator for Health Information Technology is the “foundation for health care reform?”