Meaningful Use Reimbursements Update

CMS just released the most recent data (PDF) on Meaningful Use reimbursements to date (actually to Nov 7th).

Notice the dark green Lone Star splotch. Texas EPs and hospitals have thus far gotten 20% of the $1.24 billion thus far paid out nationally ($247.5 million in TX). Of that, 83% went to the Medicaid side ($205.6 million).

Texas comprises ~8% of U.S. population.

On the Medicaid side all you have to do for Year One Stage One is attest to “A/I/U” — Adopt / Implement / or Upgrade to a CHPL Certified system. You don’t have to report on any MU measures, which is why vendors such as Practice Fusion are touting the “free money” aspect of it.

Maddeningly to me, CMS has yet to report on the relative proportions of EHR vendors whose clients have attested to date. We ran that all the way up the internal ONC/CMS flagpole and got blown off — they’ll release those tabulations in “Q2 or Q3 or 2012.”

No HHS-vendor opacity politics there, ‘eh? I'd like to see relative percentages of successful attestations to date by vendor, broken out by Medicare vs Medicaid (and further stratified by MU "registrations" to date).

Just sayin'.

DEC 15th UPDATE

CMS is now happily touting that they are going to exceed $2 billion in MU incentive payments in 2011. As reported by GovernmentHealthIT.com

• Almost 30 percent of eligible providers and 60 percent of hospitals have now registered for the incentive programs.
• Total incentive payouts under Medicare and Medicaid are now over $900 million each through November,
• Thus, total payouts for 2011 will easily exceed $2 billion – of which close to a third of total incentive payouts for 2011 occurred in November alone.

This was to be expected. After all, a huge year-end bubble of 2011 MU attestors will complete their 90-day attestation period by 12/31 and file for the year one money.

(More broadly, I'm hearing that HHS is frantically shoveling money out the door for a breadth of initiatives, probably to get funding "obligated" to help immunize the money from looming deficit-hawk budget cuts.)

The article continues:

Still there are cautionary signs.

As we noted earlier, year 1 requirements under Medicare and under Medicaid are substantially less burdensome than subsequent years. While eligible providers have registered for one or other of the programs, only 4 percent have actually qualified for incentives. Also, interoperability-related criteria were among the least popular menu objectives. In addition, 2012, not 2011, is likely to be the pivotal year.

The pace must pick-up and be sustained if meaningful use is to reach its full potential, particularly for interoperability to coordinate care among providers. We expect the proposed rules for Meaningful Use Stage 2 by the end of January, if not sooner. Now that HHS has announced that providers will not have to meet Stage 2 criteria until January 2014, providers have an extra year under Stage 1 criteria without new interoperability requirements.

One observation for now. Pushing back stage 2 means that early adopters (2011 MU attestors) will spend 3 years in stage 1, during which they will have collected the bulk of the reimbursement money (~86% for Medicare EPs -- e.g., $18k, $12k, and $8k respectively, or $38k of the total $44k five year potential).

Draw your own conclusions as to the risk this might pose to the program's subsequent stages.

PROVIDER CONCERNS: "WILL THEY CUT OFF THE MONEY IN 2012?"

Some of our staff have fielded this question. My $0.02 response to the REC team:

Chief amid the most plausible speculation is the Obama veto hole card should some HIT incentives clawback legislation even get through the Senate (doubtful, IMO). Moreover, given that the funding was written into HITECH as not contingent on annual appropriations bills going forward, that would seem to insulate the money even further. Given all the acrimonious front-burner stuff facing the Hill at the moment for 2012, I am guardedly optimistic that MU money will still flow in 2012.

I think it’s safe to say there will not be any mounting of a 2/3 veto override vote regarding any emergent clawback legislation (very low probability in any event, given Senate rules) – the most overt of which has been H.R. 408, which has gone nowhere in a year (the salient recission clauses of which are SEC 301, 302 – btw, which are identical in its equivalent Senate Bill 178).

The Senate is key. The House is principally “all sound and fury, signifying nothing.” Now, in that regard, Senator Coburn – an MD, no less -- is on record favoring killing MU money (and, he has an actual vote, unlike all these Beltway HIT pundits). Nonetheless, I’m not seeing any traction on his proposal thus far.

Deven McGraw is a good cite as well, I would think, given her various insider perches.

One caveat, though: keep tabs on the accruing Poison Pill amendments to otherwise unrelated “must-pass-by-12/31” bills.

Long view big picture: the ROI case is there in any event. So, go after the MU $$$ while they are there; after all, they’re front-loaded to favor those who get in ASAP. Moreover, adroit HIT/HIE will be vital to health care organizational success irrespective of this or that federal initiative (IMO).

I could be wrong, though.

Here's what Senator Tom Coburn -- an MD, no less -- wrote in July:

“Back in Black” pp 215 – 216 Senator Tom Coburn July 2011


“End Federal Subsidies for Health Information Technology

A provision of the 2009 failed Stimulus law (American Recovery and Reinvestment Act) massively expanded the federal government’s role in health information technology. The aims many attribute to the Health Information Technology for Economic and Clinical Health (HITECH) Act sound good: using a variety of policy levers to promote the widespread adoption of health information technology and support digital sharing of clinical data among hospitals, physicians, and other health care stakeholders. However, a closer look at the data shows [sic] that Congressional action was the wrong mechanism to accomplish these goals.

Lawmakers in Congress may have been well-intended when they supported the HITECH Act, but the massive federal intrusion into health information technology is wasteful and duplicative of current business practices. According to the nonpartisan Congressional Budget Office, the use of health information technology was already projected to be widespread by the end of the decade – even without the adoption of the HITECH Act. CBO projected that, without the HITECH Act, two-thirds of physicians, approximately half of hospitals, and at least one in five critical access hospitals would still be robustly using health IT by the end of the decade. Some reports have suggested private sector health information technology in a multi-year period is far more than the federal government is projected to spend on health IT over the next decade. In fact, in a recent survey, more than half of respondents replied they have a fully operational electronic health record in at least one facility in their organization, and only 1 in 50 respondents had not yet begun to plan for the use of an EHR. The facts make it pretty clear that massive federal handouts and mandates are unnecessary to subsidize a behavior that is already being adopted on a widespread basis in the marketplace.

Additionally, the private sector has already developed compelling models for utilizing health information technology. Major health systems like the Mayo Clinic and the Cleveland Clinic all have adopted state-of-the-art health IT systems—without federal involvement. Private enterprises are leading the way in developing completely innovative approaches to health IT. Some are even exploring the development of open software for innovators to write electronic health record applications. Such an “open source” model of current business practices. According to the nonpartisan Congressional Budget Office, the use of health information technology was already projected to be widespread by the end of the decade – even without the adoption of the HITECH Act. CBO projected that, without the HITECH Act, two-thirds of physicians, approximately half of hospitals, and at least one in five critical access hospitals would still be robustly using health IT by the end of the decade. Some reports have suggested private sector health information technology in a multi-year period is far more than the federal government is projected to spend on health IT over the next decade. In fact, in a recent survey, more than half of respondents replied they have a fully operational electronic health record in at least one facility in their organization, and only 1 in 50 respondents had not yet begun to plan for the use of an EHR. The facts make it pretty clear that massive federal handouts and mandates are unnecessary to subsidize a behavior that is already being adopted on a widespread basis in the marketplace. [ did Jonathan Bush ghostwrite this part? – BG ]

Additionally, the private sector has already developed compelling models for utilizing health information technology. Major health systems like the Mayo Clinic and the Cleveland Clinic all have adopted state-of-the-art health IT systems—without federal involvement. Private enterprises are leading the way in developing completely innovative approaches to health IT. Some are even exploring the development of open software for innovators to write electronic health record applications. Such an “open source” model could help increase competition, flexibility and lower costs – all without federal action."

One way or another, we'll know before too much longer.