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Have the EHR Incentive Programs Reached a Stagnation Point?

Providers are putting their data together for meaningful use attestation for program year 2015. Here's a review of the meaningful use program over the closing months of 2015.

By Kyle Murphy, PhD

Nearly two months have passed since the Centers for Medicare & Medicaid Services (CMS) provided the Health IT Policy Committee with an update on the EHR Incentive Programs and plenty has changed in the interim.

The next meeting of the latter is little more than two weeks away — December's HITPC meeting was cancelled — at which time the federal agency is likely to address the progress of meaningful use since November.

The last anyone heard from CMS as part of this federal advisory committee all the focus was on modifications to meaningful use requirements and objectives for Stage 3 Meaningful Use, and perhaps rightfully so.

Many eligible providers — mainly eligible hospitals — were hoping CMS would provide them with some kind of relief heading into 2016 and a full year's worth of meaningful use reporting for Stage 2.

Thankfully for them, the administrators of the EHR Incentive Programs reduced the reporting period to 90 days and placed both eligible professionals and hospitals on the same calendar for reporting purposes. However, CMS also laid out its plan for Stage 3 to begin in 2018, likely to their chagrin.

All these regulatory changes aside, eligible providers are still in the midst of putting together their data together for meaningful use attestation for program year 2015, which will need to be submitted within the next two months.

With that in mind, here's a review of the meaningful use program over the closing months of 2015.

Provider count and payments by stage

The figures provided by CMS paint a rather muddled picture of how providers fared last year, particularly in Stage 2.

As of September, more than 300k EPs and 4.4k EHs had successfully demonstrated Stage 1 Meaningful Use. Many fewer experienced success with Stage 2 — 57,726 EPs and 1,553 EHs.

September 2015 meaningful use figures

In October, CMS records indicate a rather anomalous set of circumstances. In that month, the number EPs succeeding at Stage 1 skyrocketed to 652,928 and the number of EHs grew nearly four-fold to 16,786. However, the amount of payments do not reflect that kind of growth.

EPs to that October date had received $7.89 billion, up from $7.88 billion in the previous month. Similarly for EHs, the amount went from $11.63 billion to $11.65 billion.

A similar phenomenon occurred relative to Stage 2 as far as EHs are concerned. Prior to the meaningful use modifications rule, these providers had to attest according to the fiscal year, which means after September. The number of EHs successfully demonstrating Stage 2 rose from 1,553 in September to 2,407 in October.

October 2015 meaningful use figures

So why the "phenomenon" label?

In the CMS meaningful use update for September, that last figure appeared as 1,580 rather than 2,407. What's more, the provider counts for Stage 1 became 307,656 EPs and 4,498 — consistent with September 2015 figures.

Until CMS speaks again at another HITPC meeting, these figures will remain problematic.

November 2015 meaningful use figures

Total payments for meaningful use

If judged entirely on the merits of Stage 1, meaningful use has proved a resounding success. In the first three years of the EHR Incentive Programs which began in 2011, CMS paid out increasingly larger amounts of incentive payments. For program year 2011, the federal agency doled out $5.31 billion. In subsequent years, that figure grew to $9.68 billion and $10.01 billion, respectively.

A dip in pay-outs for program year 2014 and beyond likely speak to the difficulties providers faced in moving from Stage 1 to Stage 2. In the previous program year (i.e., 2014), CMS paid out $6.64 billion. And thus far for program year 2015 for which EPs cannot attest just yet, the figure is a meager $148 million compared to previous years.

All told CMS has disbursed $31.80 billion to eligible providers, a figure that should see a significant increase in coming months if the changes to the EHR Incentive Programs truly addressed the concerns of participating providers.

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