Impact Insights

Week in Review 10/16/15 – and new White Paper on the MU Final Rule

REACTIONS TO THE MEANINGFUL USE FINAL RULE… Now that the dust has settled somewhat, industry stakeholders have finally had a chance to digest the MU Final Rule that CMS published last week.  From the reactions we have heard directly from our clients (as well as the reactions we have read online) providers seem to be largely relieved that the 2015-17 changes were finalized – but they are also fairly frustrated that it took so long to make the changes official.  Virtually everyone was surprised that CMS decided not to delay Stage 3, which remains optional in 2017 and required for all hospitals and EPs starting in 2018.  For more reactions from specific industry stakeholders, we recommend this summary from iHealthBeat and this article in Becker’s Hospital Review.

Impact Advisors’ Thoughts Although this is a “Final” Rule, there are no guarantees at all that Stage 3 will begin in 2018 as planned, especially with Congress showing interest in getting involved.  In terms of the modifications finalized for 2015-17, we think there are two important takeaways that delivery organizations should be aware of:

  • The changes to the structure of the public health objective could end up being a major problem for some EPs – especially specialists.  The immunization public health measure used to be part of the “core” set of measures.  If an EP didn’t administer immunizations, he or she would simply attest to an exclusion; that measure did not need to be “replaced” with a different public health measure.  Under the new format though, EPs have to meet 2 of 3 public health measures in 2015-17.  If an EP does not administer immunizations, he or she will have to claim an exclusion – and by default will have to successfully attest (or qualify for an exclusion) to both of the other two public health measures.  Although the Final Rule is intended to “reduce the burden” on providers, the reality is that this change in the public health measures could essentially amount to a new – and unexpected – requirement for some EPs (particularly specialists).
  • The language is still extremely vague on which transport mechanisms can be used to transmit a summary of care record.  CMS relaxed the requirement that providers have to use Direct, stating in the Final Rule that as long as the summary of care record is generated by CEHRT, providers will just need to transmit the C-CDA “electronically.”  However, there is no explicit language specifying which types of electronic transmission will – or will not – meet this new, broader requirement.  Our initial interpretation is that sending the C-CDA via secure email would probably count in 2015-17, but that sending a fax would probably not.  Either way, without further guidance from CMS, many providers will (justifiably) not feel 100% comfortable with any option other than Direct.

[For more discussion on these meaningful use issues, make sure to read our recently published summary and analysis of the MU Final Rule, which is available in the Thought Leadership section of the Impact Advisors website!]

NEW DATA ON EHR MARKET SHARE AMONG AMBULATORY CARE FACILITIES… A new report from Peer60 finds some interesting trends among certain ambulatory care facilities in terms of EHR market share (i.e. what has been implemented) versus EHR “mind share” (i.e. the EHRs providers are thinking about implementing).  For example, among hospital-owned ambulatory care facilities, Epic and Cerner were first and second in market share (and tied for first in “mind share”).  Although athenahealth had less than 5% of market share among hospital-owned facilities, the company was actually third in terms of “mind share.”  Among independent ambulatory care facilities, NextGen was the leader in terms of market share, followed by Epic – but the leader in terms of “mind share” among independent facilities was actually eClinicalWorks (with Epic and Cerner tied for second).  It is also worth noting that the top two EHR-related challenges cited by all respondents were “missing functionality” (mentioned by 55%) and “usability” (42%).

Impact Advisors’ Thoughts:  We found the report fascinating – with a lot of interesting data.  We think the chart on market share in particular does a good job of illustrating the sometimes stark differences in the EHRs used by different types of ambulatory care facilities.

IN CASE YOU MISSED IT… Although not healthcare-specific, it is definitely worth noting that the recent acquisition of EMC by Dell is the largest tech deal ever According to USA Today, the deal is valued at approximately $67 billion, or roughly $33.15 a share.

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