Naomi Levinthal MA, MS, CPHIMS, Senior Consultant, The Advisory Board Company

The electronic health record (EHR) incentive programs (i.e., Meaningful Use [MU]) headlines of late are mostly negative. One could conclude from these stories that Stage 2 is a total failure, but based on data from current attestations, past trends and College of Healthcare Information Management Executives (CHIME) survey data, we project that 95 percent of eligible hospitals (EHs) may eventually attest to Stage 2. Industry groups should use this data to encourage the Centers for Medicare & Medicaid Services (CMS) to offer shortened reporting periods in 2015.

65 percent of eligible hospitals already attested with several weeks to go

Some analyses of attestation data conclude that only a third of EHs demonstrated MU in 2014, but the number is much higher when we account for the fact that MU requires a step-wise journey through each stage. A total of 2,563 EHs were slated to attest to Stage 2, and in early December the CMS data shows that 1,681 did so (or 65.6 percent) – with several weeks still remaining in the reporting window. Eligible professionals (EPs) have until February 28, 2015, to attest, thus it is premature to draw conclusive insights. In fact, it is difficult to draw conclusions about MU trends until the final months of any reporting year because most providers wait until the final days to attest. The 2014 EH Stage 2 trends support this, as the cumulative month-by-month attestation count was: 10 in July, 143 in August, 840 in November, and 1,681 in early December (the reporting window closed December 31).

Furthermore, 2014 was not a year to test the true viability of Stage 2 because CMS changed the reporting options available. In September, CMS acknowledged how difficult it had been for providers to obtain the required upgrades needed in 2014. They finalized a policy that allowed those who experienced these delayed upgrades or were unable to fully implement the upgrade a way to essentially “roll back the clocks” and report on different sets of measures and objectives. For example, an EH scheduled to meet Stage 2 in 2014 could report Stage 1 measures alternatively. A CHIME survey estimated that about one-third of EHs scheduled to meet Stage 2 would use the alternate reporting options this year. If that estimate holds true, together with current attestation volume more than 95 percent of EHs would have demonstrated MU in a year when it appeared near impossible to do so.

Shortened reporting periods supported by data

CHIME and others call for a shortened MU reporting period in 2015. Our experience guiding Advisory Board members with their attestations shows that providers do best when they are able to choose from more than one reporting period. We find that the shorter 2014 reporting period allowed providers to shift their plans as necessary. For example, many of our members at the outset of federal fiscal year (FFY) 2014 planned to monitor performance for the second or third reporting quarter. Most, if not all, of our members had to move those plans back to either the third or last quarter. A longer than three-month reporting quarter in 2014 would have most likely derailed their entire MU effort.

Detailed attestation data from The Office of the National Coordinator for Health Information Technology (ONC) provide another data source that complements the need for shorter reporting periods in 2015. This data shows that providers are only just meeting the required thresholds. CMS could choose to shorten reporting periods on this fact alone. Those that have met the demands of Stage 2 make it with much smaller volumes of patients included in these measures’ denominators (which are based on numbers of patients seen or admitted/discharged during a set period of time).

A close examination of the information shows that when the final attestations are in for Stage 2, it will not likely be a failure. However, the facts also show that this success is, to a large degree, due to a shorter reporting period. Those supporting the Flex-IT Act can use these details to make the case that a shorter reporting period is required to make the future stages of MU successful
as well.

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