Home > EHR, meaningful use, Medicare > Meaningful Use in 2014: Early Rookie Participation Numbers Very Low

Meaningful Use in 2014: Early Rookie Participation Numbers Very Low

Every month, representatives from the Centers for Medicare and Medicaid Services (CMS) and Office of the National Coordinator for HIT (ONC) provide a report to the HIT Policy Committee regarding registration and attestation statistics for the EHR Incentive Program, or “Meaningful Use” (MU). These updates are usually unremarkable in that an overly optimistic view is portrayed via registration numbers, month-to-month incremental improvements, and total dollars paid. However, the November 2014 MU attestation statistics were more interesting than usual.

So far, only 43,898 eligible professionals (EPs) have successfully attested for MU in CY 2014. Of those, only 11,478 EPs have attested to Stage 2 MU. While low, the CY 2014 numbers should exponentially rise by the MU attestation deadline of February 28, 2015 for two important reasons: 1) the vast majority of MU attestations historically occur at the last possible minute, and 2) CMS’ September 2014 rule change to allow continued use of 2011 certified EHR technology (CEHRT) for qualifying participants. Therefore, it is hard to conclude anything about the program’s health by just looking at the November totals.

The aforementioned “interesting” part is this… Only 15,481 of those 43,898 attestations were from first-year MU participants. Recall that the attestation deadline for rookie EPs to avoid 2015 payment adjustments via MU compliance passed on October 1, 2014. Therefore, the November 2014 statistics in the report to the HIT Policy Committee included all rookie participants who made that deadline. In other words, these 15.5k rookies appear to represent the highest possible increase that can occur in MU participation rates in CY 2014 beyond the previous years (under the most optimistic of circumstances).

It gets a bit more complicated though… Recall that CMS reopened the significant hardship exception application period until later this month for the specific subset of participants who were unable to fully implement 2014 Edition CEHRT in time for a CY 2014 reporting period. While this “extension” was clearly meant for veteran MU participants who already had 2011 Edition CEHRT, it is unclear how many rookie MU participants might claim that particular hardship exception and have it hold up to audit (I expect at least several thousand will). So, we should anticipate at least a handful of rookies will attest for MU in CY 2014 using 2011 Edition CEHRT, AND will avoid 2015 penalties via the extended hardship exception.

All of that said, my point is this… Unless the “new participant” stat increases by hundreds of thousands, and not merely tens of thousands, the number of U.S. physicians who will be penalized throughout next year for noncompliance with MU is going to be staggeringly high.

Categories: EHR, meaningful use, Medicare
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