With the first day of autumn behind us, the foliage is beginning its annual transformation in many parts of the country. Mornings are becoming a bit crisper in some areas, and it won’t be long before we experience relief from the summer heat. In a recent blog post, I described some relief that Health and Human Services (HHS) brought to bear this year on those of you participating in meaningful use. As the title implied, however, the relief served up by HHS is likely to be “too little, too late.” In response to the final rule, the medical community has risen to the occasion. In a strongly worded letter to the Secretary of HHS, authored by a broad coalition of representatives from organized medicine, a request was made to substantially shorten the 2015 reporting period. Perhaps not coincidently, Congressional members Renee Ellmers (R-NC) and Jim Matheson (D-Ut) introduced H.R. 5481. Cleverly titled the “Flexibility in Health IT Reporting Act,” the bill seeks to shorten the meaningful use reporting period in 2015. Many of us are heads down in 2014, but today let’s look forward a few seasons and unpack the potential impact of HR 5481.
Dismal success with Stage 2
The uproar in the letter to HHS is well founded. At issue is the expectation that all providers (docs and hospitals) will use a 12-month reporting period in 2015. Some of you may not be aware, but hospitals report meaningful use based on a fiscal year, which begins on October 1. The numbers posted in the letter to Secretary Burwell tell the story. The majority of U.S. hospitals are due to report Stage 2 in 2015. As it stands today, the 3,800 hospitals in this boat will need to begin collecting Stage 2 data on Wednesday. To date, however, only 143 hospitals have managed to clear the Stage 2 hurdles in 2014.
Nephrologists find themselves in a similar situation as they are lumped in the meaningful use provider category labeled “eligible professionals” or “EPs.” If the rules do not change, 237,000 EPs will need to be prepared to collect Stage 2 data on January 1, 2015. Granted EPs have until the end of this year to get ready for 2015, but to date a paltry 3,152 EPs have successfully attested for Stage 2.
Stage 1 relief as well
HR 5481 is a remarkably simple bill to understand. If it comes to fruition as written, all providers, regardless of the Stage they face, would see the 2015 reporting period reduced to a calendar quarter. The idea is to replicate the unique 2014 meaningful use reporting period. In addition to providing some much-needed leg room for providers facing the Stage 2 objectives in 2015, this bill provides relief for those having trouble with timely adoption of 2014 certified technology (also referred to as Stage 2 certified EHRs). The number of providers in this boat is also detailed in the letter to the Secretary.
On Wednesday of this week, the 1,200 hospitals that will face Stage 1 in 2015, must have a 2014 edition certified EHR in place and ready to capture data. Likewise, when January 1, 2015, rolls around, the remaining 290,000 EPs facing the Stage 1 objectives in 2015 must be ready to collect MU data using a 2014 edition certified EHR as well. Based on conversations I have had with colleagues across the country, that date will be a stretch for many.
Although unmentioned in the bill, the impact this legislation could have on providers a year from now is also worth noting. October 1, 2015, is the current transition date for ICD-10. I say current because this date has been delayed at least four times, but as it stands we are about 367 days away from what will likely be a painful transition. If Congress does the right thing and passes this bill, many of you will have the opportunity to knock out meaningful use in the second quarter and avoid the remarkable hassle of dealing with the ICD-10 transition in the midst of a meaningful use reporting period.
The seasonal transition between summer and fall is one of my favorite times of the year. Heat and humidity give way to crisp blue skies and the hardwood trees begin to glow. Relief from summer heat may not be on the mind of Congress, but our legislators do indeed have a welcomed opportunity to ease the pain many will face next year. As the days grow short, let’s hope they rise to the occasion.