CMS officials have been getting an enormous amount of “heat” regarding the Meaningful Use program since the start of the Stage 2 proposed rule. Provider concerns were mostly ignored since 2012, but events over the past couple of months indicate the initial stages of capitulation on the government side of things. The Meaningful Use program is officially in a state of chaos. This blog post is the first in a three-part series that discusses how we got where we are today, what the recent signals of capitulation are and how providers should plan for Meaningful Use in 2016.
Meaningful Use Stage 1: Success
The Meaningful Use Program’s first stage was an overwhelming success. The Federal Government recognized that the healthcare system was falling behind other industries in the digital revolution and decided to subsidize the industry. There is no argument that Meaningful Use subsides spurred EHR adoption and that certified EHR systems were able to successfully digitally record patient encounters. I like to refer to the first stage of Meaningful Use as the car-building stage. Mostly, we built EHRs like we would build cars: fully capable of being driven – but unlike the car industry, we had very few roads to drive them on.
Meaningful Use Stage 2: The burden is born
In the second stage of Meaningful Use, providers were looking for their EHR investment to really pay off. Using our car analogy, we wanted to sprint down the digital superhighway and discover what other industries have already accomplished regarding interoperability and data exchange. Instead, against the advice of almost every physician organization, we got a set of very proscriptive rules that increased the burden on providers. When I first read the Stage 2 rule, my impression of CMS’ point of view was this: “Hey providers, you have the car, now you need to build the highway, too.” Highway building is complex and expensive. Providers want interoperability and a free flow of data, but they are not the healthcare constituents that are best positioned to be responsible for the construction of those roads.
Meaningful Use begins to become a broken program
In 2014 we began to see the rift between CMS mandates and what was practically achievable within the EHR vendor and physician communities. Many sub-par EHR vendors could not keep up with the pace of change and the healthcare ecosystem was just not mature enough to support the initial Stage 2 mandates. By the middle of 2014 it became obvious to every observer of the Meaningful Use program that Stage 2 was failing. It was at that time that CMS should have re-shaped the program. Instead, they patched it up by allowing Stage 2 providers to attest to Stage 1 measures. The problem was kicked down the road to 2015.
2015: Lesson Learned? Not exactly
By the beginning of 2015, we learned that CMS would again be revamping the Meaningful Use program for the 2015 attestation year. At that point, we know that a program must be in turmoil if new rulemaking for a measurement period is actually happening during the same period. What’s worse is that the rulemaking wasn’t final until October 2015. At the same time, we received the final version of the new Meaningful Use Stage 3 rule, which was also uniformly panned by most all provider organizations.
A loss of trust
All of the last minute changes in the Meaningful Use program over the past two years weigh on the psyches of physicians. Just keeping up with the complexity of the program is a full time job. Losing the trust of physicians was an unnecessary byproduct. Meaningful Use never needed to be stressful for healthcare constituents; instead it could have been the exciting program we all anticipated at its onset. Unachievable mandates have lead to a chain of last minute program adjustments and finally to an exhausted provider community.
Stay tuned for our next blog posts on this matter.