Stage 3 Meaningful Use – Cost Versus Benefits


With the introduction of the proposed Stage 3 rule and another wave of EHR enhancements right around the corner, most providers and hospitals have already concluded the cost to participate in the Meaningful Use incentive program far outweighs any expected incentive payments. At this point, we anticipate a number of providers and hospitals are questioning their decision to participate in the incentive program and many may be performing a cost benefit analysis to help reinforce their decision.  To assist with that analysis, we encourage providers to consider the following:

Participation Cost

  • System Implementation & Maintenance Costs – As estimated by the Congressional Business Office (CBO)

Chart 3

  • Annual Attestation Cost Burden – As estimated by CMS
    •  EPs to attest to EHR technology, objectives and associated measures, and electronically submit the clinical quality measure is $633 (6 hour 52 minutes at $92.25 per hour)
    • EH and CAHs to attest to EHR technology, objectives and associated measures, and electronically submit the clinical quality measure is $435 (6 hour 52 minutes at $63.46 per hour)
  • Program Administration – While the overall administration cost may vary greatly by provider and hospital, the incentive program requires some level of ongoing support to plan and manage system enhancements, training, risk analysis, audit requests, etc.
  • Performance Monitoring – Throughout the attestation period, many providers and hospitals allocate staff to monitor ongoing performance and address deficiencies
  • Patient Engagement Initiatives – Knowing that a number of providers and hospitals struggled meeting the 5% patient engagement measure, we anticipate additional resources (i.e., equipment, staffing, outreach, etc.) will be required to meet the proposed Stage 3 25% measure
  • Public Health Agency Initiatives – By increasing the public health reporting requirements, additional staffing and/or vendor services will be required to maintain an ongoing submission
  • Coordination of Care – With the introduction of the Coordination of Care measure that requires systems to accept patient generated data, we anticipate additional responsibilities will be added to the clinician’s workflow to reconcile patient data
  • Penalty for Non-Compliance – Payment Adjustments – In weighing the cost of participation, one also needs to understand the implications of not participating and its impact on future Medicare payments. Payment adjustments vary by Eligible Professional, Eligible Hospital, and Critical Access Hospital.

Benefits Realization

In weighing the benefits of participation, we recommend providers assess their performance to-date related to the desired program outcomes:

  • Better clinical outcomes
  • Improved population health outcomes
  • Increased transparency and efficiency
  • Empowered individuals

As providers and hospitals continue to use EHR, we expect increasing technology proficiency to start bringing benefits and efficiencies.

For any provider or hospital whose EHR implementation was hurried or those taking the “check the box” approach to meet the regulatory requirements, there may be opportunities to further align their deployment with clinical workflows to deploy/enable the full breadth of their EHR capabilities.

For any Meaningful Use participant, we recommend engaging your EHR vendor to review your deployment decisions and understand what, if any, capabilities were not enabled as part of your initial implementation.  A full review of features, functions, workflow, etc. may allow staff to leverage capabilities not currently in place today and additional or unexpected benefits.  We also recommend participants engage other providers using similar technology to share experiences and lessons learned. Only after fully leveraging EHR capabilities can you answer, “Is it worth it?”

Jennifer Schenck 3

Jennifer Schenck, a North Highland expert healthcare practitioner, co-authored this post.  Jennifer has worked with large healthcare service organizations in the development of their Meaningful Use programs.

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