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Not So Fast – Why It Pays to Wait Until FY 2012 on Meaningful Use

The registration process and reporting period for the meaningful use incentive program officially commenced on Jan. 3. More than 21,000 health care providers have registered to date and many more are ramping up efforts to meet meaningful use criteria and collect federal incentives in fiscal year 2011. However, rushing out the gates in FY 2011 is extremely risky and not advisable. In fact, the Advisory Board Company strongly recommends waiting until FY 2012 to first demonstrate meaningful use.

Three key reasons hospitals should wait until FY 2012 are outlined below.

Compressed, unreasonable timeline for achieving Stage 2: The final rule states hospitals that first demonstrate meaningful use in FY 2011 will need to achieve Stage 2 by FY 2013 (i.e. Oct. 1, 2012). Furthermore, hospitals must demonstrate meaningful use requirements for the entire year in Stage 2 as opposed to the 90-day reporting period for the first year that a hospital is a meaningful user. Unfortunately, the final rule defining Stage 2 requirements will not be finalized until mid-2012, leaving hospitals that first demonstrate meaningful use in 2011 with less than six months to meet Stage 2 by Oct. 1, 2012. This will be an unattainable leap for health care providers, especially because Stage 2 is being positioned as a step down from Stage 3, not a step up from Stage 1. Stage 2 comprises enhancements to Stage 1 requirements in addition to a host of new, more complex criteria and clinical quality measures. Furthermore, hospitals will be dependent on their vendors’ ability to rapidly develop, test and seek certification for the Stage 2 EHR capabilities, adding another barrier to provider Stage 2 meaningful use achievement in the short time frame available. In contrast, waiting until FY 2012 to first demonstrate meaningful use will afford hospitals nearly 18 months to migrate from Stage 1 to Stage 2 — a more adequate time frame to acquire, implement and adopt the required capabilities for Stage 2.

No incentives lost for starting in FY 2012: In order to maximize the incentive collection across all four payment years (Medicare incentives for hospitals end in 2016), hospitals must demonstrate Stage 1 of meaningful use no later than July 2013 and continue to successfully demonstrate subsequent meaningful use stages. This means that hospitals have no early mover financial advantage for achieving meaningful use in FY 2011 (other than the net present value of the incentives). However, while there is no financial upside for achieving meaningful use in FY 2011, hospitals run the risk of forfeiting their Medicare incentives in FY 2013 and beyond if they fail to successfully demonstrate future stages. Therefore, hospitals are better off delaying reporting on meaningful use until FY 2012 (i.e. Oct. 1, 2011, to Sept. 30, 2012) so that they have adequate time to prepare for Stage 2 (by Oct. 1, 2014 for hospitals first achieving meaningful use in FY 2012), thereby safeguarding their ability to maximize their incentive collection.

Building with a more complete information set: CMS and the Office of the National Coordinator for Health IT already have released several FAQs and clarifications on demonstrating various meaningful use requirements. Undoubtedly, more are on the way based on the challenges and pitfalls faced by health care providers who attempt to achieve meaningful use in FY 2011. Some of these clarifications could significantly impact hospitals’ meaningful use plans and strategies. Furthermore, across the coming months, the Health IT Policy Committee will evaluate the initial results of the meaningful use program and provide recommendations for Stage 2 and some Stage 3 requirements. Herein lies the late mover advantage for hospitals — those providers that wait to demonstrate meaningful use until FY 2012 will not only benefit from lessons learned by the early movers but also will have greater visibility into future requirements, enabling appropriate planning in a timely manner.

Recommendations Hold True for Physician Practices

In fact, the same rationale and recommendations hold true for hospitals aiming to collect Medicare incentives for their physician practices. Similar to hospitals, physicians also have to achieve Stage 2 of meaningful use by Jan. 1, 2013 (physician meaningful use schedules are based on the calendar year) if they first demonstrate meaningful use in CY 2011. Making the leap to Stage 2 in six to nine months after the release of the final Stage 2 rule will be impossible for most practices for the reasons discussed above. Furthermore, Medicare-eligible physicians do not lose any incentives for reporting on meaningful use in CY 2012 instead of CY 2011. Thus, waiting to report on meaningful use until CY 2012 for physician practices — owned or supported by affiliation — is strongly recommended.

This post originally ran on iHealthBeat.

Protima Advani is the practice manager for the IT Insights program at the Advisory Board Company. She has authored best practice studies on IT governance, data analytics and selecting IT metrics for effective dashboards.

The views expressed in this column are those of the author and do not represent the views of the California HealthCare Foundation or the Advisory Board Company.

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TylerGary LKimBobbyGGary Levin MD Recent comment authors
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Tyler
Guest
Tyler

I was reading this article http://www.beckershospitalreview.com/healthcare-information-technology/california-bill-on-emr-track-changes-altered.html. Could someone explain why patients not seeing their history makes any sense?

Gary L
Guest

After 40 years of medical practice in a variety of settings with and w/o EMR in a VA, in the DOD no one who sees Patients using an EMR is pleased, except that it automates some tasks, but detracts from dr-pt care. It gives the paper pushers something to do.

Kim
Guest
Kim

Call me naive – but coming from an IT background and also being witness to the huge strides in technology based on ‘electronic records’ of any kind – how can you dispute the value of an EHR in a medical setting – it’s been a long time coming compared to the rest of the business world. Meaningful Use is only a way to establish criteria for data to be used in a meaningful way – in order to provide an HIE in the future. Guidelines have to be established to develop and capture data that is actually usable and transferrable.… Read more »

Gary Levin MD
Guest

The commentary here has turned into a ‘flame’. Control of medicine has been wrested from physicians by payors. Absolutely everything planned by CMS, HHS and their machinations, HMOse, managed care, Medicare Advantage has done little to decrease costs, improve outcomes. The EMR debate is over it will happen, the schedule is pretty insane (very obvious, to all but the bureaucrats who used a project mangement software package with little regard to reality.

BobbyG
Guest

Yes, Dr. Levin, and I do have to apologize a bit for my hand in escalating it. It’s my Matt Taibbi gene, I guess. But, were anyone to bother to check the record throughout all the comments I’ve left here since day one, you’d find that I never ONCE initiated any kind of personal attack or otherwise absurd hyperbolic, damning statements . But I have certainly been on the receiving end, repeatedly. I should probably just ignore them. Henceforth, I will try to do better. I agree that the EMR debate is in fact over. Notwithstanding that, I am no… Read more »

Dr. Mike
Guest
Dr. Mike

Oh, I was just speaking in general terms – not trying to single anyone out. But I guess from your reply that you DO profit from burdening me with meaningful use, seeing as you are “a mere Meaningful Use technical assistance grunt”

BobbyG
Guest

You are not compelled to participate, if you see it as such a “burden.” From your quick response, It’s obvious that you are not interested in any detail I may have offered across the past year. Just clip out a dismissive one-liner. Real helpful. LOL.

DeterminedMD
Guest
DeterminedMD

It is pretty pathetic you just attack people and have to have the last word. Just remember, that is what people remember, the last word, and when it is idiotic, dismissive, and just plain rude, not many will value your last words, sir.

BobbyG
Guest

Sorry. Truly. But after a while of being repeatedly called an “idiot” a “socialist” a “democrap” etc here, one out to “enslave” doctors — and having no clue as to what they face — it just gets beyond tiresome. And I can give as good as I get.

Let’s just not bother each other any more, OK?

Mesothelioma Claims
Guest

“When you profit from the requirement to computerize the health care industry, you have zero motive to question that requirement.”

i agree with you…

Dr. Mike
Guest
Dr. Mike

When you profit from the requirement to computerize the health care industry, you have zero motive to question that requirement. I’d be happy to take your advice about how to implement new technology and systems, but I’ll make up my own opinion based upon controlled studies and my own personal experience about the value of the technology to my practice.

BobbyG
Guest

“Zero motive”? That’s rich. Were you to take the trouble to read my independent REC blog (I won’t hold my breath), you’d see that I question everything, in quite some detail. I am no unreflective cheerleader for HIT, in contrast to many of the reflexive naysayers I see here.

DeterminedMD
Guest
DeterminedMD

How ironic you two above raise this point about “meaningful use” at this site that is really moreso about “meaningless use”. Come on, folks, do you read this crap from these IT pontificaters who really have no idea what goes on in a doctor’s office, that doctors really want to spend more time in front of a screen than in front of a patient? I have respect that computers do help patient care to a degree, but if you listen to the meaningless banter by all these authors who just sell the message that Mr Holt is so eager to… Read more »

BobbyG
Guest

You are really a tiresome naysayer.

“Come on, folks, do you read this crap from these IT pontificaters who really have no idea what goes on in a doctor’s office”
__

Get lost. I spend about half of my work weeks ongoing IN doctors’ offices consulting with them and their staffs, and working hard to help them.

DeterminedMD
Guest
DeterminedMD

You have me confused with giving a damn about your opinion, SIR!

Plus I read your useless banter with Nate, so what do you want to accomplish by just bashing people because you don’t like what we say? Shout us down means you win?

Go to DC, you’ll fit right in.

BobbyG
Guest

Bashing? LOL. Let’s see, “nate” routinely calls everyone having opinions differing from his an “idiot”, a “socialist”, a “democrap”, etc. I do none of that. “Bashing” Right.

Again:

I spend about half of my work weeks ongoing IN doctors’ offices consulting with them and their staffs, and working hard to help them.

Enlighten me as to how such an observation is tantamount to “bashing”? Explain to me how it can be that I know nothing about the challenges faced by physicians.

pcp
Guest
pcp

If anyone is managing this blog (which seems increasingly doubtful), here are a couple points:

1. Posts are being moved off the front page too quickly under the new design;
2. When they are moved, they seem to disappear (where is Ms. Gur-Arie’s most recent “meaningful use” post?);
3. Many links still do not work;
4. Add a preview or edit function for posters.

Thanks

BobbyG
Guest

Copy that. They fixed some things that weren’t broken.