By Michael Burger, Senior Consultant
Back in the beginning of the Meaningful Use Incentive Program for Electronic Health Records (EHRs), I was a product manager working at an ambulatory EHR vendor. One of my jobs was to understand Meaningful Use (MU) so that we could get our EHR ready for certification. Another was to evangelize MU to our staff and our clients – explain the program, how it works, and the reasons to participate – both as a vendor and as a provider.
It wasn’t easy to pore over the hundreds of pages of regulations and requirements. But I did it, and came away at the end of the process with a firm understanding of the program and what needed to be done.
I stepped away from product management a few years ago and began a new career as a consultant. The relief I felt from not having to take another EHR through another MU certification was palpable. In the ensuing few years as a consultant, I’ve watched from the sidelines as the tug o’war raged – should MU be cancelled, should it be deferred, when will the new rules be published.
And then early this year, in almost an offhand comment, the Centers for Medicare and Medicaid Services (CMS) mentioned that MU is going away. Or at least that’s the way the industry press reported it. As it turns out, this isn’t exactly true, as the essence of MU is being blended into the new Merit-Based Incentive Payment System (MIPS), coming in 2017.
CMS’ statement has pulled me pulled back into the MU fray. I heard from a number of clients, who ask, “Now that MU is dead, how should our strategy shift?” In order to answer that question, it was necessary to delve into the requirements of MU Stage 3 and into the details of MIPS.
To say that my head is spinning is an understatement. The MU program has been “bureaucratized” to the point where it’s really challenging to understand (as if that weren’t impossible before). The stages have been rebranded as editions. The time periods have gone from a year to 90 days, the reporting periods have gone to a calendar year. Core and menu measures are no more, replaced by objectives with multiple associated measures. Measures are retired. New measures are added.
And then there’s MIPS. It’s a points-based incentive program with multiplier bonuses—not to mention a mandate to use certified EHR software. MIPS also has bonuses calculated in 2019 using 2017 performance data--even though the specific bonus requirements may not be available in time for 2017.
Now this highly confusing program is even more confusing and convoluted—so much so that even we techies and policy wonks are challenged to figure it out. Physicians are among the most highly educated professionals, trained to make life or death decisions. The program has become so confusing that it’s little wonder than physicians are confused and apathetic (or combatant) about MU and have been abandoning the program in droves, according to the latest statistics.
Government programs by definition are bureaucratic. And it is true that despite the complexity, Meaningful Use has been effective in its goal of installing the infrastructure for the digitalization of healthcare. For sure, simplification is needed. I don’t claim to have the full answer, but If we’re struggling with providers abandoning the original MU program, its replacement CAN’T be even more complicated.