January 2012

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In early December, Secretary of Health and Human Services Kathleen Sebelius announced that Stage 1 of the EHR Meaningful Use incentive program would be extended through 2013. Until the official announcement, little was known as to when Stage 2 would begin. While the extension is likely meant to invite more physicians to qualify for EHR incentives, the implications of this action for the future of EHRs in medicine are potentially wide-ranging.

User Data

Though CMS did not provide an official reason for extending Stage 1 for another year, recent data on EHR use and the progress of the incentive program point to concerning trends that may have lead to the extension. The data indicate that less than 6,000 people have attested for Meaningful Use. Moreover, only about 138,000 Medicare and Medicaid providers of the nearly 800,000 eligible have registered. Of these, only 5,805 providers attested to Meaningful Use to collect incentive dollars. These numbers are disappointing and far below what CMS expected with the rollout of its incentive program.

One possible reason for the discouraging user turnout is that some clinicians may be delaying their start of Meaningful Use qualification until after they have collected their e-prescribing incentives in 2011. Theoretically, one can possibly earn more incentive money by starting Meaningful Use this year, since you cannot qualify for both the Meaningful Use incentives and e-prescribing incentives concurrently. Nevertheless, whether or not this accurately portrays the reason for the low turnout, there is no denying that the data is disconcerting, particularly when you consider the increasing attention paid toward EHRs in recent months and years.

In light of these data, CMS’s actions to extend phase one seem to make sense. Given how smoothly Stage 1 has been thus far and the relative ease with which dermatologists and all clinicians can qualify for incentive dollars, elongating it to allow and encourage more users is a logical choice. However, although the extension may embolden more physicians to becoming Meaningful Users of EHRs, there may be some unintended consequences as a result that could hinder the development of the incentive program and more broadly EHR use in general.

For example, the incentive structure as it exists currently is set up to pay a maximum of $18,000 in 2011, then $12,000 in 2012, and $8,000 in 2013. That is a total of $38,000 that one can potentially earn by the end of 2013. But more importantly, that money would all be earned by following qualifications standards for Stage 1. This leaves only a total of $6,000 remaining for clinicians to earn for the remaining stages of the program, in 2014 and beyond. While it may be encouraging that clinicians can earn $38,000 simply be meeting the guidelines for stage 1, the extension of stage 1 does not bode well for physicians continuing on with the program, given that the latter stages will undoubtedly be more difficult to qualify for and will pay out less than stage 1. Therefore, moving forward, CMS will likely face the issue of whether to raise the maximum dollar amount for the overall program, which it could very well do if the user data continues to disappoint.

Conclusion

In general, both physicians and vendors are likely to welcome the action CMS has taken to galvanize EHR use. Physicians who have not yet made the plunge into the electronic realm will have more time to both invest in an EHR and learn the protocols to qualify for incentive dollars. And on the merchant side, vendors will have more time to prepare for and adapt to the forthcoming regulations of stage 2. This is likely why the government extended the deadline. However, both vendors and physicians are still likely to gear their efforts for stage 1 and perhaps be less ready or willing to participate in the later stages, which could cripple the program and the development of EHRs in medicine. One way this unintended consequence could be avoided is if HHS adds more incentive money to the “stage 2 and 3 years.” But in terms of the here and now, I recommend that dermatologists who are considering an EHR system implement soon. Not only will you be eligible for the maximal incentive amount, but also most of the money can be obtained while still only complying with stage 1 of meaningful use (see sidebar).

But the caveat remains: Only buy a system that makes you more efficient.

Watch Dr. Kaufmann discuss the status of EHRs in Dermatology at DermTube.com. Scan the QR code at right with your Smartphone or log onto: dermtube.com/video/electronic-healthrecords/

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