EHR early birds may or may not get the worm

The end of the first year of Stage 1 of the Medicare hospital electronic health-record incentive program is coming Sept. 30. Hospital officials wanting to receive payments have 60 days after that to submit their data to the CMS and attest that their organizations have been meaningful users of a certified EHR for at least 90 days during fiscal 2011.

And yet, potential pitfalls await these early adopters.

For one, their meaningful-use clock will reset Oct. 1. After that, providers must be meaningful users under Stage 1 criteria for 365 days. Then, under Medicare rules, hospitals must meet what will be almost certainly more-stringent Stage 2 criteria, starting Oct. 1, 2012.

Stage 2 criteria remain a work in progress. Current expectations are that they won't be out until mid-2012. If Stage 2 rules aren't released until June, hospitals will have just four months to upgrade EHR systems. And that's only if IT vendors have their Stage 2-certified systems ready.

So, for their hustle, hospitals will gain bragging rights (and maybe a marketing advantage) and the value of receiving Medicare incentive payments this year. Whether those rewards offset the risks is a calculation both hospital and group practice leaders must soon make. Physicians and other "eligible professionals" seeking EHR incentives will have only a few months more to react than hospitals because their program runs on the calendar year.

In February, the Advisory Board Company, a management and IT consulting firm, issued guidance urging its clients to wait until fiscal 2012 before starting their climb up the meaningful-use staircase. The consultants counseled the money will be the same—roughly $7.2 million for a "typical" 200-bed hospital with 20,000 discharges and a 40%/20% Medicare/Medicaid patient mix—whether they go now or wait until next year.

Protima Advani, the Advisory Board's strategic research director, says the advice to wait still holds, even though the federally chartered Health IT Policy Committee advised the Office of National Coordinator in June that providers choosing to become meaningful users in 2011 ought to get some slack.

The CMS folk have seen the recommendations, Advani says, "but they're not saying whether they will or will not follow those recommendations."

"I am sticking with my guns for a couple of reasons," she said. The CMS was "very vocal" during a recent webinar that the timetable in the current rule remains unchanged. "If you were to hold to the letter of the law, you must accept you're going to have to be there (at Stage 2) by Oct. 2012."

For those on the fence, Advani advises, "Run your data, but if you don't see something solid before November 30, by all means don't push your 'submit' button." Instead, Advani recommends that eligible providers apply for Medicaid incentives (available in 27 states) because of the initially lower threshold requiring providers to "adopt, implement or upgrade" a certified EHR but not demonstrate meaningful use.

It's hard to argue with that recommendation. What do you think?

Follow Joseph Conn on Twitter: @MHJConn.



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