If healthcare IT leaders weren’t already overwhelmed with priorities and must-do items on their to-do lists, they might well stop to pause at the sheer number of deadlines and other time-sensitive elements to consider under healthcare reform and meaningful use. Both the Affordable Care Act (ACA) and the American Recovery and Reinvestment Act/Health Information Technology for Economic and Clinical Health (HITECH) Act, through its meaningful use process, are imposing federal mandate after federal mandate on hospital organizations and on physicians (and therefore on physician organizations as well, of course) in the next several years; and keeping track of all the deadlines and other time-related elements under both legislative programs will continue to be a source of confusion and frustration for many, going into the foreseeable future.
What’s more, the healthcare reform-related mandates are coming under three main mandatory programs: the value-based purchasing program, the healthcare-acquired conditions reduction program, and the avoidable readmissions reduction program. And of course, as providers move into Stage 2 of the meaningful use process, the requirements become both more numerous and more complex.
And of course, there is the mandatory transition to the ICD-10 coding system as well; a transition whose specific trajectory is somewhat clouded at the moment by the decision of the Department of Health and Human Resources (HHS) to postpone the universally mandatory transition date of Oct. 1, 2013, without immediately announcing the replacement date.
In the midst of all this, Erica Drazen, Sc.D., who this week is retiring as partner in the Waltham, Mass.-based Global Institute for Emerging Healthcare Practices at the Falls Church, Va.-based CSC, last week gave HCI Editor-in-Chief Mark Hagland an industry-exclusive interview, along with industry-exclusive publication rights to two charts she and her colleagues have developed (see Figures 1 and 2 below), which layout in graphical format the broad web of timelines and deadlines under all these programs, for the next couple of years (see image gallery for both figures). Below are excerpts from that interview.
Figure 1 [For higher resolution images of these figures, please check the gallery in the upper left hand corner.]
It was quite a process to put these figures together, wasn’t it?
Yes! It was a huge challenge to find all these dates. And I finally found a document from CMS [the federal Centers for Medicare and Medicaid Services] that talked about physician quality reporting and e-prescribing, together. Most of the time, most of the e-prescribing stuff is presented year by year. And the other thing that’s amazing is how quickly it changes.
You devoted many hours to this; I can only imagine that the average physician in group practice would be totally at sea with all these overlapping deadlines from the various programs.
And imagine the poor solo physician! You can’t find out the consequences of being an e-prescriber and a meaningful user submitting data, except through this one document. And the penalty for not being an e-prescriber and a meaningful user is 2 percent and then 4 percent of revenues, the reimbursement cut: in 2018, the doc penalty is 4 percent of Medicare reimbursement. For hospitals, it’s a percentage of their annual update.
And I had to color-code the years, because look at what happens in 2012 for docs. How could you possibly keep track? It’s very complicated, it’s not easy to figure out, there are lots of nuances to it, and the other thing that a lot of people don’t realize is, the penalties apply to everyone. And some docs are going to participate under Medicaid. But if you apply to the Medicaid program and don’t fulfill your requirements, you will still be penalized under Medicare, even though Medicaid has no penalties. And 30 percent of your population has to be on Medicaid to get the Medicaid incentives. And the Medicaid incentives are bigger. But if you don’t meet the meaningful use requirements under one of the programs, you will still penalized under Medicare.
Do people even know that?
I don’t think so.
What are some key things that hospital people don’t know?
Well, the hospital side is clearer; but one of the things that people may have overlooked is that the last time you can attest to meaningful use and avoid any penalties, if it’s your first year, is by July 1 of 2014. You have to have met the requirements and attested to any stage, by July 1, 2014. It’s not when you need to start, it’s when you need to finish, to avoid penalties in 2015. And if it wasn’t your first year, you had to be a meaningful user throughout 2013, in order to avoid the penalties in 2015.
So there are two ways to avoid penalties—there’s kind of the ordinary way; or, if it’s your first year, everything has to be done by July 1, 2014, to avoid penalties in 2015. And it was always true that the penalties would begin in 2015, but it wasn’t clear what the performance standards would be.
What are the biggest misunderstandings in the industry about all this?