POCP Blog

By Michael Burger, Senior Consultant

On March 11, the Health IT Policy Committee endorsed the Meaningful Use Workgroup’s recommendations for Meaningful Use Stage 3.  The Workgroup’s initial proposal was scaled back by 30%, eliminating 8 of the 26 initial measures.  The Policy Committee’s recommendations now go to the Centers for Medicare and Medicaid Services (CMS), which will develop a proposed rule later in 2014, with a final rule expected during the first half of 2015.

Reports are that the March 11 meeting was contentious, with many participants dismayed at the outcome – but for different reasons.  Some expressed concern that decisions were being made without applying feedback from Stage 2, now just getting underway.  Others stressed that with Stage 2 and ICD-10 looming, providers and EHR vendors are overwhelmed – and that the requirements should be reduced even further.

Forceful and eloquent arguments could be (and have been!) made about the merits and demerits of Meaningful Use.   The intent of MU remains pure – investing in the technology infrastructure with which to put public health policy into action.

The challenge, as with all things public policy, is that the intent is often obscured by the reality of the real world.  Given that there has never been widespread organic demand for EHRs, it shouldn’t be a surprise that use of EHRs that have been adopted as a result of incentives is faltering. Nor is it surprising that providers are opting to not continue with the MU program in year two.  The intent – putting public health policy into action – is obscured by the reality:  Using an EHR requires commitment, change management and a big picture view.  Physicians aren’t seeing the good that could come from EHRs because they’re bogged down going through the motions to pass the MU test.

Why Not Medication Adherence?

From that perspective, it’s interesting to look at what’s “in” and what’s “out” for Stage 3.  While I was not a participant in either the Meaningful Use Workgroup or at the HIT Policy Committee, I will say some of the choices do not make sense.  One troubling choice was the decision to remove a requirement related to Medication Adherence.

Medication Adherence (or compliance) refers to a patient’s conformity to a physician’s recommendations about medication therapy treatment with respect to timing, dosage, and frequency.  Med Adherence is a valuable EHR feature because it has the potential to have an immediate and measurable effect on public health.  Monitoring and taking proactive steps to remind and encourage patients to stick to their medication care plan will result in an enormous improvement in public health, in addition to sizable reduction in spending.  For diabetes alone, it has been estimated that increases in medication adherence of only 20% could reduce total health care spending by $1,074 annually for every person with diabetes.[i]

Compare that to the proposed requirement requiring providers to record electronic progress notes which are text-searchable.  Electronic progress notes refer to visit documentation that is recorded either as text (i.e. word processing) or as individual fields of data (i.e. as a template); versus handwritten dictated, or scanned documents.

For electronic progress notes, the intent is that one phase builds upon another until the goal is reached. Text-searchable notes lead to codified notes, which lead to interoperability and data mining of notes, which leads to population-wide progress note analytics.  The intent makes sense – in the big picture.    The reality is that in the physicians’ view, electronic progress noting increases the amount of time a physician spends to document a visit, reducing productivity (and revenue) and does little to improve population health in the short term.

Perhaps it’s time for CMS to consider the time tested acronym– WIIFM – What’s in it for me?  If all a physician sees is a bunch if “must do” MU requirements and doesn’t see WIIFM, they’re not going to stick with the program long enough for the intent of MU to be recognized.  Requirements like Medication Adherence monitoring have a pretty clear WIIFM factor.

[i] Sokol MC, McGuigan KA, Verbrugge RR, Epstein RS. Impact of medication adherence on hospitalization risk and healthcare cost. Med Care. 2005;43(6):521–530.

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