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Thinking About Meaningful Use in a Different Light

December 22, 2015
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Are providers’ MU complaints fair or unjust?

Ever since the Centers for Medicare & Medicaid Services (CMS) released the final rule for Stage 3 of the meaningful use (MU) program in October, providers have not hidden their displeasure regarding measure thresholds and program requirements, and its overall lack of flexibility. What’s more, they want the current MU trajectory to slow down; they have urged CMS to hit the pause button, to wait until more providers have attested to Stage 2, and to focus more on interoperability rather than burdensome requirements that have led to more angst for doctors.

These are the words of physicians themselves, spoken out through groups such as the American Medical Association (AMA), American Hospital Association (AHA), and the American Academy of Family Physicians (AAFP), among others. But recently, I came across a different perspective that caught my attention from the Consumer Partnership for eHealth (CPeH), a Washington, D.C.-based patient advocacy group led by the National Partnership for Women & Families, who argued that the current structure of MU should be maintained, not overhauled.

I was so intrigued by CPeH’s meaningful use comments, also signed by 24 other consumer and health organizations, that I called its director of health information technology policy and programs, Mark Savage, to get more insight. My interview with Savage, published last week, can be read here, but in this space I want to take a deeper dive into the two opposing perspectives. It should be noted that CPeH doesn’t include providers themselves, but Savage says the Partnership does have long-term working relationships with many of the provider groups that are so outspoken against meaningful use.

During our conversation, Savage brought up some very interesting points to me, perhaps the biggest regarding the number of eligible professionals (EPs) and eligible hospitals (EHs) that have reached Stage 2 already. Specifically, the AMA and other provider organizations have pointed out several times that only 12 percent of physicians have been able to successfully participate in Stage 2 of meaningful use. "The statistic speaks volumes about how physicians embrace new technology while ill-conceived regulations hold back progress,” the AMA said in a November letter to CMS, also signed by 110 other medical associations. This 12 percent number has been one of the main points that provider organizations have hammered home in their argument that most physicians are not nearly ready for Stage 3.

Indeed, recent CMS statistics show that there are 483,233 combined EPs and EHs who are qualified for meaningful use incentive payments. The numbers also show that of those 483,233 who are eligible, a combined 62,163 have attested to Stage 2—or a little more than 12 percent, as the AMA and others have said.

However, Savage interprets this data in a different way. While yes, there are nearly 500,000 EPs and EHs in the MU program, many of those are still stuck in Stage 1, meaning they aren’t yet eligible for Stage 2. Looking again at the CMS data, there are 124,336 EPs and EHs are who actually eligible for Stage 2—not the 483,233 that is often reported. This means that there are a great deal of EPs and EHs who aren’t yet ready for Stage 2. So, in that sense, the Stage 2 attestation rate for those who are eligible for this stage is actually more like 50 percent (62,163/124,336)—not 12 percent. After all, Savage argues, how can all of the EPs and EHs who are still in Stage 1 be counted towards the Stage 2 attestation rates?

The point Savage makes is an interesting one, for sure. Perhaps, for the providers who are legitimately eligible for Stage 2, attesting isn’t as hard as is publicly perceived? On the other hand, it’s hard not to think about all of those eligible providers still stuck in Stage 1 in the fourth full year of the program.

Clearly, for many physicians, climbing the meaningful use ladder has not been easy, so when associations such as the AMA, AHA and the College of Healthcare Information Management Executives (CHIME) ask CMS to wait until 75 percent of eligible providers have attested to Stage 2 before mandating Stage 3, I think this position has real merit. I went back to Savage and brought up this point, the idea that Stage 3 should not be required as early as 2018, as currently outlined by CMS. He said that for those struggling in earlier stages of the program, there is a modified and simplified course; for example, the provider in Stage 1 goes through a modified Stage 2 in 2016 and 2017 to a simplified Stage 3 in 2018. Still, to me, it’s hard to imagine that Stage 1 provider being ready for any version of Stage 3 by 2018—simplified or not.