Each January, JP Morgan hosts the nation’s most attended healthcare investor conference in San Francisco. It took many by surprise that CMS administrator, Andy Slavitt used that platform to indicate that the end to the Meaningful Use program as we know it may be coming sooner than expected. The news shocked many at first, but the reality is that while the existing set of standards may change, they will not be eliminated entirely.Meaningful Use Rule

Slavitt remarked on a “new regime” that would end Meaningful Use and culminate with the Medicare Access and CHIP Reauthorization Act [MACRA] implementation and merit-based pay “that is flexible and adapts around the goals of a provider’s individual practice and patient population.” MACRA initially stated that the current Meaningful Use incentive payment system will end in 2018 and will be replaced in 2019 by a Merit-Based Incentive Payment (MIPS). Slavitt added that new regulation on the transition would most likely occur in 2016 (sooner than most expected), emphasizing the replacement by MIPS and alternative payment models. It seemed that he was almost critiquing has own agency when he proclaimed that “technology must be user-centered and support physicians, not distract them.”

He highlighted the following themes, among others as guidelines for the new program:

  1. Rewarding providers not just for the use of technology, but for the outcome they achieve with their patients. Physicians will continue to achieve these outcomes with the help of technology in the way they need to use it that is appropriate to their practice and patient population.
  2. Slavitt continued to highlight the major objective for technology to meet individual practice needs, rather than government needs.
  3. “Third, one way to aid this is by leveling the technology playing field for start-ups and new entrants,” Slavitt added. They will require open APIs to allow apps, analytic tools and connected technologies to get data in and out of an EHR securely.
  4. Interoperability will also become a key focus. Slavitt stressed the initiatives in collaboration with physicians and consumers toward pointing technology to fill critical cases like closing referral loops and engaging a patient in their care.

As we stated in our prior blog, only a small percentage of physicians had attested to Stage 2 of Meaningful Use by the fourth quarter of 2015 – and more than 100 physician organizations have asked Congress to delay Meaningful Use 3. Between the many complexities of Meaningful Use requirements, the tardiness of the final CMS rule, which came in October and gave providers fewer than 90 days to attest to 90 consecutive days in the 2015 calendar year, the resounding sentiment among providers has been: “too much, too fast.” As John Halamka, MD, MS, chief information officer of Beth Israel Deaconess Medical Center in Boston, Massachusetts, chairman of the New England Healthcare Exchange Network (NEHEN) and professor of medicine at Harvard Medical School, pointed out in a recent interview, the infrastructure wasn’t in place to support the requirements of Stage 2. Therefore providers couldn’t be expected to successfully jump to Stage 3. Halamka believes as we do that Meaningful Use created a good foundation for basic EHR functionality. When Meaningful Use program was first introduced, few physicians actually used EHRs; now that the majority of doctors and hospitals have adopted EHRs, Meaningful Use has served its purpose!

The Short Term is Murky

Below are abbreviated comments from a recent blog (published after JP Morgan) authored by Slavitt (CMS) and Karen DeSalvo (ONC), regarding the Meaningful Use program in the next year:

  • The current law requires that we continue to measure the meaningful use of ONC Certified Health Information Technology under the existing set of standards.
  • The approach to meaningful use under MACRA won’t happen overnight. We encourage you to look for the MACRA regulations this year; in the meantime, our existing regulations – including meaningful use Stage 3 – are still in effect.

In that blog, Slavitt seemed to backtrack a little, reminding us that we should expect a new approach to Meaningful Use – not necessarily an end to Meaningful Use. Yes, CMS and ONC felt compelled to remind us that Meaningful Use has not yet, and may not ever be completely legislated away. What we do know is that the Federal Agencies responsible for crafting the Meaningful Use rule are feeling the winds of change … but even CMS and ONC don’t know how Meaningful Use will be morphed into a more practical program.

Caution: Still Business as Usual

Until the Meaningful Use rule has been officially transformed per Slavitt’s recent communications it is business as usual for Meaningful Use. Repeat Meaningful Use providers should plan to attest for a full year and have a strategy to meet all 10 Objectives.

Conclusion

Providers and vendors are suffering from Meaningful Use fatigue. Is there an ICD-10 code for this syndrome? We are all suspect of making a complete commitment to a program that is in disarray. We don’t even know for sure that Meaningful Use as we know it today will be the same program by the end of this year. Vendors are reluctant to begin the Meaningful Use upgrade cycle until a clear path for the next few years has been etched in stone. One thing I know for sure is that providers will need to continue to work on certified technology well into the future and EHR vendors will need to continue to upgrade and certify. Let’s hope that the work we do in the future will begin to pave the healthcare digital superhighway that providers have been longing for.

You can find Andy Slavitt and Karen DeSalvo’s post on the EHR Incentive Programs: Where We Go Next, here