SEATTLE, WA--(Marketwired - May 22, 2014) - The two agencies that oversee the Electronic Health Record (EHR) Incentive Programs -- the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) -- proposed several key changes on May 20, 2014, that will give providers greater flexibility in demonstrating meaningful use in 2014. If approved, the ruling will provide relief to some providers that are experiencing vendor upgrade and certification delays. Additionally, CMS and the ONC recommended additional time to refine Stage 3 logistics and requirements; the proposal includes a provision that extends Stage 2 through 2016, with Stage 3 beginning in 2017.
Michelle Holmes, a principal with ECG Management Consultants, Inc., a Seattle-based health care consulting firm, comments that there is more to this ruling than flexibility with deadlines. "The backdrop of this news is that only 50 eligible professionals and four hospitals have attested for Stage 2 for a variety of reasons, and CMS and the ONC are facing significant dropout rates with the EHR Incentive Program because providers are struggling with Stage 2 requirements. Even the 2014 Stage 1 criteria, with their patient portal requirements, are proving difficult. Organizations are struggling to make operational changes that support patient interaction and encourage patients to engage in new ways," says Holmes.
Holmes also notes that this new flexibility will not alleviate all of the pain points of achieving meaningful use compliance and progress this year. In fact, it creates more uncertainty and challenges. "It's not clear where the burden of proof lies for providers that claim an inability to attest as planned this year due to a delay in the availability of a 2014-certified EHR version. Meanwhile, both the pre-payment and post-payment audit processes for the EHR Incentive Programs are more rigorous. CMS did not define what documentation will be required of providers during an attestation audit to justify their inability to implement a 2014 edition EHR."
Given the caveats and limitations of this announcement, ECG believes that this ruling is not the right answer for the challenges at hand. There are a variety of reasons why providers may not be able to successfully attest for Stage 2 in 2014, with availability of an upgraded EHR being just one of them. In addition, the lack of clarity and guidance regarding the burden of proof for pursuing one of the new 2014 attestation options creates a high-risk proposition as providers struggle to make informed decisions.
Holmes is skeptical about packaging this as something other than a delay of Stage 2. "This proposal could have been crafted without placing blame, creating caveats, and increasing audit risk and opportunities for misinterpretations. A blend of this proposal with the recent suggestions of partial credit from the American Medical Association would strike a simpler balance. Also, solutions that focus on operational support for providers challenged by patient engagement and interoperability requirements should be considered," says Holmes.
ECG clients are expressing frustration about the key changes, noting that after working aggressively to meet requirements, the painful upgrades might have been unnecessary. Early adopters are concerned about being penalized for already implementing a 2014-certified EHR, and those providers feel they may suffer from having to use a sub-optimal product. Some organizations are expressing their intent to largely ignore this week's announcement. Instead of bouncing from one approach to another, they will focus on a thoughtful evaluation of the benefits that the upgrade could bring and move toward a long period of stability with their EHR.
About ECG Management Consultants, Inc.
ECG is a strategic consulting firm that is leading healthcare forward, using the knowledge and expertise built over the course of four decades to help clients see clearly where healthcare is going and to navigate toward success. We work as trusted, professional partners with hospitals, health systems, medical groups, and academic medical centers across the country. We thrive on delivering smart counsel and pragmatic solutions to the critical challenges that will transform the healthcare system. Client success is our primary objective. ECG's national presence includes offices in Seattle, Boston, Dallas, San Diego, San Francisco, St. Louis, and Washington, D.C.
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