The AAFP's Center for Health Information Technology has carefully analyzed the CMS final rule that defines "meaningful use" in terms of electronic health records, or EHRs, and has determined that the final rule contains changes that will benefit family physicians. However, the rule still will require significant effort to implement, according to Steven Waldren, M.D., director of the AAFP's Center for Health IT.
According to final rule, which was published in the July 28(www.gpo.gov) Federal Register, CMS will pay meaningful use bonuses to eligible providers, including family physicians, beginning in 2011.
"The final rule contains substantive changes from (the previous) proposed version that make achievement of meaningful use more reasonable, although significant effort will still be required on the part of our participating members," said Waldren in a written report on the final rule.
Waldren highlighted the rough spots that family physicians likely will encounter as they work to become meaningful users of EHRs and earn incentives of as much as $44,000 through Medicare or $63,750 through Medicaid.
There's still time to participate in the AAFP's webinar "Understanding the Meaning of Meaningful Use" on Aug. 19 from noon to 1:30 p.m. CDT. Registration is available via a Web page dedicated to the new health information technology regulations and is limited to the first 500 participants. Cost to members is just $10. (Editor's Note: View an archived copy of the webcast(www.centerforhit.org) [Members Only].)
One area of concern to the Academy was parity between Medicare and Medicaid regarding the incentive programs' first-year requirements. That type of parity was not in the final rule.
"Eligible professionals in the Medicare program must bear a heavier burden of full meaningful use compliance in their first payment year to receive the incentive payments," said Waldren. That gives Medicaid-participating physicians, who just have to commit to adopt, implement or upgrade a certified EHR, a "significant advantage" the first year, he said.
"Upfront cost is a major barrier to adoption of health IT," said Waldren. More physicians probably would participate if Medicare's first-year requirements mirrored those of Medicaid, he added.
In addition, according to Waldren, CMS' aggressive timeline for the implementation of meaningful use will be a "significant challenge."
"We have seen prior, and significantly smaller, national health IT initiatives fail to meet expectations when deadlines trump all else," he said.
Waldren highlighted a single date: Sept. 30, 2011. That's the deadline physicians must beat to meet the final rule's 2011 Medicare requirements. Physicians must demonstrate 90 consecutive days of meaningful use in their first payment year, said Waldren, but numerous barriers stand in their way, including the
- absence of certified EHR technology in the current marketplace,
- complexity of meaningful use rules,
- difficulty of making fundamental practice changes and
- scarcity of skilled personnel to guide physicians.
"Many physicians will be running to meet the deadline, only to be frustrated when the calendar changes to Oct.1," Waldren predicted.
Jason Mitchell, M.D., assistant director of the Academy's Center for Health IT, told AAFP News Now that the lack of technical support topped the Academy's list of concerns.
He said many federally funded heath IT regional extension centers would have trouble providing the level of support that practices need. "There isn't the right amount of expertise, and there isn't enough money to put the people with expertise on the ground to help practices along," said Mitchell. "Most regional extension centers are brand-new organizations, quickly assembled and with no track record for providing the proposed services."
Mitchell added that for-profit vendors and technical assistance companies have done much of the physician mentoring to date -- although practices pay for those services. However, vendors are likely to be "pretty stretched" in the near term with so many practices needing help in such a short amount of time, said Mitchell.
Waldron and Mitchell also expressed concern that family physicians would be reluctant to participate in another government-run program similar to CMS' Physician Quality Reporting Initiative, or PQRI.
"Physicians who participated in PQRI and didn't receive payments on time or, in some cases, didn't get paid at all, aren't going to climb onboard the meaningful use train until they see that the bonus money is flowing," said Mitchell. The program's earliest participants won't begin to receive incentive payments until May 2011.
Mitchell also pointed out that implementing an EHR and then becoming a meaningful user doesn't happen overnight. Rather, "It's a six-to-nine-month process, at best, to develop competencies in the advanced feature set and to optimize the workflow changes the meaningful use (rule) requires," he said.
Therefore, September 2011 -- a scant five months from the first payouts -- looms large in the overall timeline.
Family physicians -- no strangers to CMS' penchant for tracking minutiae -- also are leery of the heavy administrative burden of meaningful use compliance.
"The reporting process likely will be more difficult than CMS estimates," said Mitchell. "And this extra administrative work that physicians are expected to do is not a part of routine patient care; it doesn't add anything to the quality of care that physicians provide to their patients."
The Academy, however, is pleased with some of the changes CMS made to the original rule. For example, CMS moved 10 of 25 measures into a "menu set" whereby physicians can select five measures to use.
Calling the change a "vast improvement," Waldren said it reduced the overall number of required measures from 25 to 20. "Though not truly a partial incentive … this new flexibility introduced in the requirements will allow practices some choices to match their capabilities and workflow processes," he said.
In the final rule, CMS also reduced the scope of computerized provider order entry to apply only to medication orders and reduced the compliance threshold from 80 percent to 30 percent of all medication orders.
Thresholds for several other utilization measures also were reduced in the final rule. In addition, CMS reduced the number of potential quality measures from 96 to 44. That means most physicians will need to submit only six quality measures; three of those will be core requirements, and the physician will choose three.
Another positive note on the final rule: The term "hospital-based" has been redefined so that physicians who provide patient care in hospital-based ambulatory clinics are no longer automatically excluded from participation in the program.