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Meeting Stage 2 Requirements: Does Size Matter?

September 7, 2012
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Despite flexibility shown by CMS, smaller providers will still face tough hurdles

How is the meaningful use Stage 2 final rule being received now that providers are taking a closer look at the mandates? In many ways the perception of the challenges has a lot to do with the provider’s resources and the progress it has already made.

I recently had an opportunity to speak with Bruce Smith, senior vice president of information systems and CIO of Advocate Health Care, Oak Brook, Ill. “We have been working diligently toward accomplishing many of the things that are in the criteria anyway,” he says. “It’s the next level for us. And we will focus on getting the [incentive] money for 2012 and 2013 and then we will deal with Stage 2 for 2014.” He adds that the health system received $25 million in 2011 and expects to receive $20 million in 2012 in CMS reimbursements. “We love the program and hope they have Stages 3, 4, and 5,” he says.

He also notes that the Stage 1 requirements have enabled the hospital put the infrastructure in place to move ahead with Stage 2. For example, he says the hospital system has the ability to meet the mandate to use secure messaging with its patients, and is building a patient portal that will go live by the first of the year. He also says he is comfortable with interoperability requirements, and that Advocate is a participant in the Metropolitan Chicago Healthcare Council (MCHC) Health Information Exchange.

Does he have any reservations? Sure. For one thing, he prefers that CMS would “synch up” clinical measures for meaningful use with other clinical measures being reported through other venues. “It would be nice if they were to pull all of that stuff under one umbrella,” he says.

Nonetheless, Smith’s reaction was far more positive than negative, and he says CMS has shown flexibility with the Stage 2 mandate. “They are looking at where the vendors are and where the industry is. They are trying to push the envelope, which is what you’d expect them to do,” he says.

Smith says his organization will press on with meeting the mandate. Yet Smith also says that providers that have not made investments in their technology platforms will face serious challenges in meeting the criteria. “You have to have an EMR, a staff of qualified people dedicated to deploying the technology, and you have to have the clinical people involved to make sure that everything is being collected and reported on,” he says. “We’ve been on this road for the last five or six years.”

Richard Temple, an executive consultant with Weymouth, Mass.-based Beacon Partners, Inc., also expressed a positive reaction to the Stage 2 rule. He is excited about the direction meaningful use is going, and he applauds the CMS for showing some flexibility in implementing an aggressive timetable for compliance.

In general, CMS met providers half way and have paid attention to feedback from providers, he says. He notes that the provision for electronic batch attestation will be “huge” for large practices. CMS “recognized how cumbersome it was to go through the process, and reacted to that,” he says. He adds that CMS has shown some flexibility in the 90-day EHR reporting period in 2014: “That’s something that came out of the fact that they are really listening to the needs of the providers,” he says.

Yet Temple also says that small physician groups and small critical care hospitals may find it tough to meet the mandates. Their limitations boil down to a question of resources, and both types of organizations may be forced to rely on outside help to meet the mandates.

Small practices often lack the financial wherewithal to make the necessary investments to invest, and may lack the IT and process know-how to properly validate that all of the proper things are happening, both from a technology perspective and a process perspective, he says. Some small practices simply don’t have the people to pull together project plans or create dashboards to track numbers on a real-time basis. “Even as these systems are able to give it to you, you have to be able to do something with it to hit those numbers,” he says.

Critical access hospitals are in a similar bind. Meaningful use requires a concerted effort in which people are available to monitor the core measures and menu items, and take a team-based approach to identify and fix items that fall below a threshold, he says. “Someone has to be there whose prime responsibility is to do that,” he says. “In places where there is no bench resource to do that, it is daunting.” Temple acknowledges there are plenty of other problems as well: limited or no broadband access and no access to HIEs. To CMS’ credit, it has put in a mechanism for providers to claim hardship exemptions. “The good news is that they put that in; to what degree of rigor they use in approving the hardship remains to be seen,” he says.

Nevertheless, Temple says meaningful use “is bringing to the fore things we have wanted to do forever” in terms of HIE, electronic order entry, and having data presented in a discrete kind of way that it can be mined for quality improvements. The next big hurdle, he says, is how to harness big data in a way that really drives quality, where data shows significant leaps in some areas and not in others. “How do we drill down and justify those areas that are problematic and judiciously deploy what is necessary?” he asks.