Once again, Meaningful Use (MU) is in the news, as it was reported that the Stage 3 proposed rule could be published as soon as February 2015. According to the summary on the Office of Management and Budget’s site, the Stage 3 proposed rule will include “changes to the reporting period, timelines, and structure of the program,” and those changes “will provide a flexible, yet, clearer framework to ensure future sustainability of the EHR program and reduce confusion stemming from multiple stage requirements.”
Many hospitals and health systems probably feel like that is a pretty big promise after such a turbulent year for the program. After all, Meaningful Use – for better or for worse – was definitely one of the biggest healthcare IT-related stories in 2014. So before we get too far into 2015, I wanted to take a minute to reflect on what I personally took away from working on number of MU-related projects and closely following guidance from CMS and ONC over the last 12 months.
CMS seemed awfully reluctant to offer flexibility ahead of time last year. Despite initially holding firm on timing and certification requirements in 2013, we finally saw CMS respond to concerns in 2014 by issuing a number of “fixes” throughout the year. First we had the new category of hardship exception, followed by the relatively last minute announcement of “special” 2014 reporting periods for hospitals and EPs dealing with certification issues, and then most recently, the extension of the 2014 submission deadline for hospitals.
Unfortunately, this cycle of establishing tough requirements, sticking to them amid significant pushback, and then having to make relatively last minute changes does not help anyone long term. CMS and ONC lose needed credibility with providers and vendors, while those providers and vendors are faced with making important business decisions without really knowing for sure what to expect when it comes to final deadlines and actual requirements.
Higher than expected attestation numbers in 2014 only told half the story. Far more providers were able to successfully attest to Meaningful Use in 2014 than many had originally expected (and to be fair, some of this was unquestionably due to the aforementioned “flexibility” from CMS’ special 2014 reporting periods that allowed some providers to use old software or attest to Stage 1 instead of Stage 2). On the surface those numbers are a good thing: a higher number of providers than most people anticipated were able to earn incentive payments and/or avoid a penalty.
There is a negative that doesn’t get quite as much news coverage though: the sheer time and resources that were required to make that happen. In some hospitals and physician practices (especially smaller or independent sites), the process of meeting the objectives and measures in 2014 actually seemed to become so all-consuming from an IT perspective that there was literally no bandwidth for much else. Strategies around patient engagement and data exchange in particular struggled to gain traction if not explicitly required for Meaningful Use.
Frustration is growing, and it is not a certainty that the program can endure another year as turbulent as 2014. To be clear, it is extremely unlikely (at least in my opinion) that Meaningful Use will simply “go away” any time soon – the government has invested far too much money for that to happen. But there are certainly valid questions about whether the program that was originally envisioned will be able to sustain, especially if providers decide that the penalties pale in comparison to the investment required to avoid them.
2014 was an interesting – but also quite turbulent – year for the MU program. There are many lessons that can be learned; the list above is my personal takeaways. As we look to 2015 and the proposed Stage 3 rule, perhaps the real question is what did CMS and ONC learn over the last year? Will they be able to deliver on a promise of a “flexible, yet, clearer framework? Only time will tell, but we should know a lot more about Meaningful Use in 2015 – and the role the program will play in the future – after the Stage 3 proposed rule is published in the Federal Register, perhaps as soon as next month.