As we enter 2013, the second full year of the CMS EHR Incentive Program is now complete. CMS continues to update their web site with the latest numbers, and recently the December 2012 figures were released. Reviewing these numbers permits us to examine participation rates and to garner a better understanding of size of the financial incentives that have been paid since the program began.
How Many?
To date over 180,000 eligible professionals and 3,500 hospitals have successfully participated in the CMS EHR incentive program. The number of physicians registered for the program is approaching 300,000. As you may recall, there are three basic paths to meaningful use: the Medicare path, the Medicare Advantage path and the Medicaid path. The Medicare and Medicaid paths define an eligible professional (EP) slightly differently. Medicare EPs include physicians, dentists, oral surgeons, optometrists, podiatrists and chiropractors. The list of Medicaid EPs includes physicians, dentists, certified nurse-midwives, nurse practioners and in specific circumstances physician assistants. In my experience, the vast majority of nephrologists take the Medicare path, as the Medicaid eligibility criteria are difficult for nephrologists to meet. To date almost 2,400 nephrologists have successfully participated in the Medicare arm of the meaningful use program. Depending on whose denominator one uses, that’s 30-35% of the nephrologists in practice today. The provider summary table from the CMS website compares 2011 to 2012.
A quick back-of-the-envelope calculation informs us of a few things. In the stage 2 final rule, the Department of Health and Human Services utilized data from the Congressional Budget Office and the Government Accountability Office to determine there will be approximately 565,000 EPs and 5,000 hospitals potentially impacted by this program. Let’s focus on the Medicare EPs as this is the bucket most nephrologists find themselves in. According to the stage 2 final rule estimates, there were just north of 380,000 nonhospital-based EPs who were uniquely eligible for the Medicare incentive in 2012. (They were not part of a Medicare Advantage program nor were they eligible for the Medicaid program.) As noted above, there were just over 106,000 Medicare meaningful users as of the end of 2012, or roughly 28 percent of those eligible to play. These numbers fall short of the Department of Health and Human Services original predictions. The updated estimates in the stage 2 final rule predict meaningful use in this group of EPs will exceed 50% in 2016, with roughly two thirds of the EPs demonstrating meaningful use by 2019.
How Much?
A tremendous amount of money has changed hands during the course of this program, and as 2012 came to a close, the total payout for the program surpassed $10 billion. As displayed in the table below, the bulk of this money went to hospitals; however, EPs have collected over $3.5 billion during the program’s first two years. Closer to home, the 2,400 nephrologists taking the Medicare path to meaningful use have received a respectable $43 million to date. To add some perspective to the nephrology figure, in 2010 when the PQRS and eRx incentives were at their peak of 2 percent, 1,900 nephrologists collected $11.8 million for participating in PQRS and almost 1,000 nephrologists collected $6.2 million from the eRx program.
What’s Next?
Adoption is moving at a slower pace than ONC and CMS originally anticipated, but all signals I see imply this ship has sailed. I think 2013 will be a relatively quiet year for nephrologists and meaningful use. Those who have had success during the first two years are very likely to participate again as the objectives, with minor exception, remain the same and the financial incentive remains robust. Nephrologists who waited on the sidelines for the first two years will consider dipping a toe in the meaningful use pool for the first time during 2013. The reasons for doing so include the fact that the Medicare incentives begin to decline this year ($15,000 vs. $18,000 for the year-one incentive). Perhaps more importantly, demonstrating meaningful use in 2013 is one of the ways nephrologists can avoid the 1.0% penalty in 2015. The excitement for our specialty will begin next year as 2014 heralds the arrival of the more rigorous stage 2 objectives. We will explore that topic in the near future.
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