The challenges physicians face in their efforts to meet meaningful use (MU) require focus and appropriately allocated resources that are often overlooked. It has been reported that over 20 percent of providers have already dropped out of the incentive program, with the numbers expected to rise during Stages 2 and 3.
Moreover, 21 percent of eligible providers who were subject to pre-payment audits, and 23 percent of those subject to post-payment audits, did not meet the meaningful use criteria and had to forego their incentive payments. The Centers for Medicare & Medicaid Services (CMS) anticipates recouping approximately $18 million from physician MU audits over the course of the program. However, now that CMS has proposed an easing of the Stage 2 requirements, many physicians who thought they could not meet the higher thresholds are likely to be able to successfully attest with appropriate guidance.
In April 2015 CMS issued proposed modifications to the incentive program, which would change the timeline, structure, and requirements for providers regardless of program stage or year. These changes should have a positive impact on the rising MU dropout rate, making the program more feasible for a majority of providers.
While the proposal offers much needed relief in several areas, including patient engagement, it also introduces elements of high risk. More than ever, providers need experienced resources to help them understand the detailed changes to the program and develop a strategy for how to proceed in 2015.
Understanding physician-specific MU
- Do you know the requirements physicians must meet in the current and proposed program?
- Have you developed a 2015 strategy, to focus on those requirements that need attention now versus those that can wait until the final rule is published?
- Do you know the difference between MU requirements for hospitals and physicians?
- Is MU part of the onboarding process for new physicians?
- How are you handling audit preparation for your physicians?
These questions are a good starting point for the types of conversations that should be occurring in your organization around MU. It is important to keep in mind that the 2015 proposed modifications are not final and are subject to change after the 60 day comment period, with the final rule not expected until late summer/early fall of 2015. Providers who work towards the modified rule assume the risk that all proposed changes will not be finalized as they currently stand. Critics of the proposed modifications claim the changes are too dramatic, jeopardizing the progress made in previous years and failing to prepare physicians for the hike in Stage 3 compliance. These criticisms may impact the outcome of several requirements in the final rule. However, if providers wait until the final rule is published to attain MU, they run the risk of not having enough time to meet challenging requirements.
Developing a specific strategy for MU in 2015 will mitigate some of the risks associated with the uncertainty of the final rule. Providers should identify which current requirements must be tackled now in order to prevent last minute calamities, while postponing efforts that can be easily achieved in the brief time allotted after the final rule is published.
While many of the MU requirements may look similar for hospitals and physicians, upon closer inspection you will see that physicians are required to meet additional patient engagement standards, targeted preventive care efforts, and have to provide more documentation to patients. Currently, physicians need to encourage patients to view/download/transmit their electronic health information and send secure messages, both of which present time consuming workflow challenges and necessary training/education. The proposed rule substantially reduces these patient engagement requirements, but physicians should not depend on this reprieve. Providers need to continue to focus on patient engagement, regardless of the proposed changes in order to mitigate risks in Stages 2 and 3.
- Do you have an individual responsible for overseeing/managing physician MU compliance efforts?
- Who is registering and attesting for each physician?
- Who is selecting menu and clinical quality measures for each physician?
- Who is monitoring each physician’s compliance reports?
- Who is completing a physician-specific security assessment?
- Are physicians aware of their compliance status on each MU requirement?
- Who is identifying the need for MU training among physicians?
- Who is responsible for capturing and maintaining audit documentation for each physician?
Individual physicians are ultimately responsible for meeting meaningful use, which means each physician needs to singularly comply with all requirements in order to successfully attest. This responsibility becomes clouded, however, when the incentive payment is allocated to a practice, hospital, or health system.
MU preparedness is often compromised due to failure to identify the appropriate project oversight structure and lack of communication with the physicians. It is essential, therefore, to lay out each stakeholder’s role in the EHR incentive program early in order to avoid preparedness shortcomings.
Incorporating MU into existing organizational processes will also help reduce some of the challenges for physicians. Since a physician’s MU status (i.e., stage, year, incentive payment, penalty, audit) will follow him/her between practices, it is important to capture this information in your organization’s onboarding process. Onboarding is also a good time to discuss MU requirements and expectations, including how incentive payments and penalties are handled in your practice. MU workflows, including electronic documentation standards, should be incorporated into new and existing physician/staff training sessions. MU processes should become the norm in your organization rather than an auxiliary effort.
Marc Grossman is a principal at the New York City-based accounting firm WeiserMazars’ healthcare IT practice, and has been providing IT strategic consulting services to healthcare facilities throughout the U.S. over the last 20 years. Jenna Barsky is a manager of the company’s healthcare practice.