Beginning in 2015, participation in the EHR Incentive Program for Medicare will lead to either an incentive payment or payment adjustment for eligible professionals (EPs). For the first time, EPs (excluding those eligible for the EHR Incentive Program for Medicaid) will have their payments reduced by one percent each year they do not achieve meaningful use up to a maximum of a five-percent decrease.
Obviously, the motivation behind payment adjustments (i.e., penalties) is to get more providers adopting and meaningfully using certified EHR technology (CEHRT) in their practices. The question that remains is: Are these penalties enough to compel non-participants in the EHR Incentive Programs for Medicare to join the program?
When asked about the efficacy of these payment adjustments last year, meaningful use opponent Richard Armstrong, MD, FACS, told EHRintelligence.com that the penalties lacked the necessary teeth to prompt non-participating providers to adopt EHR systems certified for meaningful use:
First, the penalties aren’t that severe, so what I would say to most physicians is, “Don’t be nervous about these things. Don’t worry about it. Just don’t install it because it’s just going to cost you more money to try to keep up than the penalty.” The second is the entire meaningful use thing — I will quote the head of IT who is a doctor from Henry Ford Health System that has 2,000 physicians. He wrote an article and said, “Meaningful use is not meaningful, so we’re not going to do this.” And basically what he said is the truth.
The Centers for Medicare & Medicaid Services, however, is hedging its bets that payment adjustments will do the trick. Recently, the federal agency overseeing the EHR Incentive Programs released a report providing details about two other reporting programs, one of which is extremely pertinent to meaningful use, the Electronic Prescribing (eRx) Incentive Program.
In the 2011 Reporting Experience, CMS is optimistic that the “impressive growth” of the eRx program, which is in many ways a precursor to the EHR Incentive Programs, has likely something to do with the introduction of payment adjustments that began in 2012.
In the 2011 program year, CMS paid out $285,049,103 in eRx Incentive Program payments (a five-percent increase over the previous program year) to 174,189 EPs and 43,132 practices. Over that same time period, participation in the e-prescribing program increased by 116 percent.
During the first year of payment adjustments, 135,931 EPs were subject to these penalties with a vast majority (80%) resulting from complete non-participation. Meanwhile, a series of exemptions (e.g., hardships) prevented 543,545 from suffering the same fate.
While the two programs share many similarities, they are still only analogous at best. The eRx Incentive Program has allowed for a number of reporting methods via claims, registries, and EHR systems while the EHR Incentive Programs requires CEHRT. That being said, payment adjustments have some effect on getting more providers to join up; however, it doesn’t seem to be as significant a jump at least during the first year of penalties.
When coupled with the cost of adopting an appropriate EHR system and going through the motions of meaningful use (e.g., implementation, training, reporting), the stick may actually appear more attractive to non-participants than the carrot.
