Nov 6: What if Your EHR Isn’t Certified for Meaningful Use Stage 2?
On January 1, 2014, stage 2 of the Centers for Medicare & Medicaid Services (CMS) meaningful use incentive program begins for physician practices.
But there’s a major problem. Most of the doctors who met the requirements for stage 1 aren’t going to be able to meet the requirements for stage 2. Why? Their electronic health records (EHRs) aren’t up to the task. And neither are their vendors.
If your EHR can’t handle stage 2, you have a decision to make — and quickly. Do you keep the current EHR that you paid a king’s ransom for a couple of years ago (and toward which you most likely feel a Shakespearean level of rage), or do you replace it with a system that’s more user-friendly and can not only meet the requirements for stage 2 but hopefully won’t leave you high and dry when the requirements for stage 3 go into effect inexorably on January 1, 2015?
Out of more than 2200 products and nearly 1400 complete EHRs (with practice management components) certified for stage 1 meaningful use criteria, only 75 products and 21 complete EHRs are certified for meeting stage 2 criteria.
“Our very conservative estimate is that about 90% of vendors are not going to be ready for meaningful use stage 2 at the start of January,” says Emily Peters, Vice President of Communications at Practice Fusion, an EHR vendor in San Francisco, which has just issued a guarantee to its 100,000 customers that its product will be 2014 meaningful use-ready before the year is out.
However, most vendors are unlikely to ever to meet stage 2 meaningful use requirements, because the market for EHRs is glutted and they don’t have a large enough slice of it to justify the investment.
“It’s a scary time out there,” Peters concedes. “Hundreds of vendors are certified on the market today, which is an unsustainable number of EHR vendors.”
As a result, she says, “we’re calling this a Darwinian mass extinction event that’s happening with EHRs. Going into this sector, we always knew that there was going to be an event at some point: a mass consolidation — that something had to change. Our perspective is that stage 2 is going to be that event.”
Because this is a known and widespread dilemma, and since the Office of the National Coordinator for Health Information Technology (ONC) oversaw the certification of the first batch of EHRs for stage 1, many doctors hoped that the agency would extend the deadline for meeting the requirements for stage 2 until everyone — or at least most doctors — had workable tools for doing so.
This is what the American Medical Association (AMA), the American Hospital Association (AHA), the American College of Physicians (ACP), and the Medical Group Management Association (MGMA), among others, urged in formal letters to Health and Human Services Secretary Kathleen Sebelius last summer.
They are still waiting for a reply. Stage 2 goes into effect very soon (January 1, 2014). The clock is ticking. The deadline, as of now, stands.
If your EHR can’t meet stage 2 meaningful use requirements, pressure your vendor for a realistic date for when the upgrade will occur, suggests Ronald B. Sterling, MBA, President of Sterling Solutions, a health information technology consultant in Silver Spring, Maryland.
“If your vendor’s messed up, I would first stay on top of the vendor to find out what the heck is going on,” he says. “Are they ever going to be able to do it?”
Also write to CMS, which administers the meaningful use program, Sterling urges. What are you supposed to do? You bought an EHR that was certified. You shouldn’t be penalized for vendor failures beyond your control. Ask CMS to extend the deadline for meeting stage 2 criteria.
With letters to this effect from the AMA, AHA, ACP, and MGMA already on the spike, you may wonder whether this is a futile gesture.
“We’re pretty skeptical that the deadline will be extended at this point,” says Peters. “Maybe later this year.”
“Our feeling about why they wouldn’t extend it has more to do with political process than whether it’s a good or a bad idea,” Peters elaborates. “ONC is in the midst of a transformation. They’ve just appointed a new director. They have some very strict goals that they’ve been trying to hit. They’ve been hitting them. My feeling is that they will wait and see how bad the fallout is before they decide to extend the deadline.”
But a deadline extension is no help if your vendor still can’t upgrade your EHR in time to meet it. If it can’t, you have 3 options, Peters says: Go back to using paper charts; continue to use your current EHR, but drop out of the meaningful use program, lose the bonuses, absorb the penalties, and kiss membership in a patient-centered medical home or Accountable Care Organization goodbye; or do what many doctors have been telling surveyors that they are planning to do anyway: Get a new EHR.
Should you get a new EHR, even though you probably paid a fortune for your current EHR just recently?
“There’s an economy lesson here on first movers’ disadvantage,” Peters offers by way of perspective. “The people who invested in EHRs early, all the way up to a Kaiser Permanente putting billions of dollars into a system, are seeing a bit of a challenge: ‘Okay, I bought this Model T car and now everyone else is driving around in Honda Accords.'”
But it isn’t just early adopters who are finding that their old EHRs are suddenly obsolete. A group of doctors in small practices is in the midst of suing the largest EHR vendor, Allscripts Healthcare Solutions, for failing to upgrade the EHR they were sold and then trying to force them to switch to a far more complex server-based system, with an entirely different architecture, that they were initially told by the firm was designed for large physician practices, not small ones. Some practices purchased the now-defunct Allscripts EHR in 2012.
Server-based systems, at least for smaller practices, are on the way out, Peters is convinced. “It’s a technology platform problem,” she says. “Over the past year in the EHR sector, more and more vendors are moving to cloud- or Web-based rather than server-based EHRs, because you eliminate the upgrade problem.”
With server-based systems, a consultant has to physically visit your office to do the upgrade. For a vendor with thousands of customers, that’s a major production, with a price tag to match that gets passed on to those customers. With a cloud-based EHR, “you just roll out an update and all of your users are on it,” Peters says. “It’s a much easier technical solution.”
“What the sector is doing with this meaningful use stage 2 culling activity is flushing out a lot of the server-based solutions and moving to the cloud,” she says.
Sterling, the EHR consultant, has reached the same conclusion about the likely need for many practices to switch products: Many vendors will not have the ability to upgrade their systems on time — or possibly ever — leaving their customers little choice but to look for a new EHR.
But Sterling cautions that moving to a new system is not a quick fix. On the contrary, transferring patient data from one EHR to another can be daunting. It’s labor-intensive, time-consuming, error-prone, and expensive for practices making a switch. However, as EHR vendors gobble each other up and the industry continues to consolidate, many doctors will face the same problem that the doctors who purchased the Allscripts product now face.
“A number of other products are out there were acquired by someone else, and their doctors were told, ‘We’re going to move you to our latest and greatest, next-generation product,” Sterling says. “And then you’re stuck trying to compensate for the differences between those products” — a trend expected to continue.
With the clock ticking, “I’m of the thought that you rip off the bandage,” Peters says. “Stage 2 is coming fast, and Stage 3 is right behind it. An extension won’t necessarily help. If I were a doctor in a small practice today, using an EHR that was looking a little unstable, I would say, ‘OK, it’s now Q4. Between now and December, I’m switching to a different system.'”
But how do you rationalize walking away from a $50,000, $100,000, or even larger investment and starting over from scratch? One way to view it is that you’re probably looking at a significant expense whether or not you switch.
“Should you throw good money after bad? It’s not just your initial massive investment that will continue to smart,” says Peters. “In most situations, that vendor is coming back to you now and saying, ‘Can I have another $10,000 to upgrade you? Can I have $1500 to connect you to each of your labs? Can I have another couple of thousand dollars to set you up with a patient portal?”
“It’s a very difficult conversation that you have to have,” she concedes. “‘Do I want to spend another $30,000 on the system I already have, or do I want to look elsewhere and see what else I can do?'” Source