Penalties Loom for Lagging on E-Health Initiatives

The incentives offered for early adopters of the various electronic health initiatives promulgated by the Centers for Medicare and Medicaid Services are expected to transition into penalties within the next 2-3 years.

Currently, the Electronic Prescribing, or eRx, program offers both incentives and penalties. However, the Electronic Health Record (EHR) and Physician Quality Reporting System (PQRS) programs, which still offer incentives for participating, will transition to penalties by 2015.

The EHR incentive program authorized up to $27 billion for incentive payments to hospitals and physicians for "meaningful use" of a qualified electronic health record. Surgeons and other physicians qualifying for the first time last year and this year could receive up to $18,000 in the first year and annual payments through 2016 totaling $44,000.

During 2013 and 2014, there will be a reduced incentive for initial qualification, and beginning in 2015, failure to demonstrate meaningful use will lead to a penalty of 1% in Medicare reimbursement. That penalty increases to 2% in 2016 and to 3% for 2017 and beyond.

Dr. Margaret Tracci, a vascular surgeon at the University of Virginia Health System who has analyzed these programs and their potential effects on surgeons, projects that penalties for surgeons who don't meet the requirements for any of the programs could reach 5.5% in 2018.

The overall emphasis on primary care in the initial program rollouts may have made surgeons less attuned to the concept of electronic reporting and record-keeping, according to Dr. Don Detmer, medical director of the American College of Surgeons (ACS) Division of Advocacy and Health Policy. "It let some surgeons think they could put it off," he said in an interview. "We started out with some carrots, but the carrots are becoming sticks. Still, it's not like this hasn't been known from the beginning."

Ways to Participate

The ACS doesn't have a good sense of how many surgeons and which types of practices aren't prepared for these programs to transition to penalties. Nonetheless, EHR adoption may have outpaced adoption of the PQRS and eRx, because many surgeons are using some form of electronic health record, according to Dr. Tracci. There's less participation in electronic prescribing programs or in PQRS as of yet, she said.

PQRS, which began in 2007 as an incentive program for voluntary reporting of quality measures, will transition into penalties for nonparticipants beginning in 2015. Surgeons who don't report data for PQRS will be hit by a 1.5% Medicare reimbursement penalty in 2015 and a 2% penalty in 2016. Conversely, there's a 0.5% incentive available for Maintenance of Certification (MOC) for those who participate in PQRS through a qualified entity.

Surgeons and other "individual eligible professionals" may report selected measures by several mechanisms, including claims-based, registry-based, or EHR-based mechanisms. There's also a group practice reporting option, although the deadline already has passed for groups to select this option.

For PQRS, "there are three registries surgeons can use to participate now [but] we really are on our own collecting and submitting data," Dr. Tracci said. Several hundred institutions nationwide have formed their own registries, she added.

A 2009 CMS report indicated that surgeons are far more likely to report PQRS data when they participate in their own group's registry. However, there are no recent data indicating just how many surgeons are participating, according to the ACS.

The electronic prescribing, or eRx, incentive program provides an incentive to use a qualifying electronic health record to generate and transmit eligible prescriptions for Medicare beneficiaries. This program begins transitioning to its penalty phase this year.

To avoid penalties, individuals and groups must generate a set amount of e-prescriptions. "In practice, it has been much harder for surgeons to meet the requirements than primary care physicians," said Dr. Tracci.

Pay Now or Pay Later

EHR programs are admittedly expensive to implement, but the penalties for failing to do so can add up into the millions over the life of the program for a physician group of several hundred surgeons and other doctors, Dr. Tracci noted.

While her group at the University of Virginia is "in a position to do this" and maintains an EHR system that meets meaningful use requirements, she said, most practicing surgeons are in smaller groups, and will have a tougher time implementing EHR. And some practices have invested in EHR, only to find that the product they've chosen doesn't suit them and they need to switch. "That is incredibly costly, and also costly in terms of productivity," Dr. Tracci said.

Many enterprise-wide EHR products "are not well suited for subspecialty data requirements," noted Dr. Detmer. "When you get right down to it, when you put in an EHR, it's not about electronics, it's about changing the way you work. Once you make the transition -- and it usually takes a couple of months -- most folks would rather not go back."

The ACS is getting more engaged in an effort to help surgeons cope with the deadlines, he added. Surgeons who haven't started on any of these programs first should carefully analyze the reporting periods for all of the incentives and penalties when prioritizing which program to begin first, according to information provided by the ACS health policy division. "For example, this is the last year you can begin the stage 1 of the EHR incentive program to be eligible to receive the full incentive bonus of $44,000. The first 6 months of the year is also one of the reporting periods to avoid getting the 2013 eRx payment penalty," according to the ACS.

The time and money involved also should play a role in decision making. Keep in mind that the eRx and PQRS programs both have relatively low start-up costs, and do not take a long time to begin.

More Information

The ACS provides information focused on each quality program -- eRx, HER, and PQRS -- where surgeons can find resources such as flow charts and step-by-step guides to help lead them through the process of implementation:

-- ACS Division of Advocacy and Health Policy: www.facs.org/ahp/index.html

-- EHR: www.facs.org/ahp/ehr/index.html

-- eRx: www.facs.org/ahp/erx.html; www.facs.org/ahp/erx-exemption.pdf

-- PQRS: www.facs.org/ahp/pqri/index.html

However, "if you get into this, you will need to have someone in your group really spend some time with it," Dr. Detmer cautioned. In addition, he noted that there can be long waits for installation of popular products, which surgeons need to keep in mind while considering when the EHRs need to be operational to avoid CMS penalties.

In general, institutions are much further ahead on EHRs than are surgeons practicing solo or in small groups, Dr. Detmer said. "Most people who are in an institution or large system are typically well into this at this point," he said. "If they haven't made the move to [electronic] order entry, they're doing it right now."

In institution-wide efforts involving multiple specialties, "surgeons don't necessarily have to lead, but surgeons will need a champion as part of the process," he added.

With the new subspecialty certification in medical informatics now available, "there really is a need for some young surgeons to decide they need to be part surgeon, part informatician," Dr. Detmer said. "We have some good surgeons involved in this, but not the numbers we need."

The incentives offered for early adopters of the various electronic health initiatives promulgated by the Centers for Medicare and Medicaid Services are expected to transition into penalties within the next 2-3 years.

Currently, the Electronic Prescribing, or eRx, program offers both incentives and penalties. However, the Electronic Health Record (EHR) and Physician Quality Reporting System (PQRS) programs, which still offer incentives for participating, will transition to penalties by 2015.

The EHR incentive program authorized up to $27 billion for incentive payments to hospitals and physicians for "meaningful use" of a qualified electronic health record. Surgeons and other physicians qualifying for the first time last year and this year could receive up to $18,000 in the first year and annual payments through 2016 totaling $44,000.

During 2013 and 2014, there will be a reduced incentive for initial qualification, and beginning in 2015, failure to demonstrate meaningful use will lead to a penalty of 1% in Medicare reimbursement. That penalty increases to 2% in 2016 and to 3% for 2017 and beyond.

Dr. Margaret Tracci, a vascular surgeon at the University of Virginia Health System who has analyzed these programs and their potential effects on surgeons, projects that penalties for surgeons who don't meet the requirements for any of the programs could reach 5.5% in 2018.

The overall emphasis on primary care in the initial program rollouts may have made surgeons less attuned to the concept of electronic reporting and record-keeping, according to Dr. Don Detmer, medical director of the American College of Surgeons (ACS) Division of Advocacy and Health Policy. "It let some surgeons think they could put it off," he said in an interview. "We started out with some carrots, but the carrots are becoming sticks. Still, it's not like this hasn't been known from the beginning."

Ways to Participate

The ACS doesn't have a good sense of how many surgeons and which types of practices aren't prepared for these programs to transition to penalties. Nonetheless, EHR adoption may have outpaced adoption of the PQRS and eRx, because many surgeons are using some form of electronic health record, according to Dr. Tracci. There's less participation in electronic prescribing programs or in PQRS as of yet, she said.

PQRS, which began in 2007 as an incentive program for voluntary reporting of quality measures, will transition into penalties for nonparticipants beginning in 2015. Surgeons who don't report data for PQRS will be hit by a 1.5% Medicare reimbursement penalty in 2015 and a 2% penalty in 2016. Conversely, there's a 0.5% incentive available for Maintenance of Certification (MOC) for those who participate in PQRS through a qualified entity.

Surgeons and other "individual eligible professionals" may report selected measures by several mechanisms, including claims-based, registry-based, or EHR-based mechanisms. There's also a group practice reporting option, although the deadline already has passed for groups to select this option.

For PQRS, "there are three registries surgeons can use to participate now [but] we really are on our own collecting and submitting data," Dr. Tracci said. Several hundred institutions nationwide have formed their own registries, she added.

A 2009 CMS report indicated that surgeons are far more likely to report PQRS data when they participate in their own group's registry. However, there are no recent data indicating just how many surgeons are participating, according to the ACS.

The electronic prescribing, or eRx, incentive program provides an incentive to use a qualifying electronic health record to generate and transmit eligible prescriptions for Medicare beneficiaries. This program begins transitioning to its penalty phase this year.

To avoid penalties, individuals and groups must generate a set amount of e-prescriptions. "In practice, it has been much harder for surgeons to meet the requirements than primary care physicians," said Dr. Tracci.

Pay Now or Pay Later

EHR programs are admittedly expensive to implement, but the penalties for failing to do so can add up into the millions over the life of the program for a physician group of several hundred surgeons and other doctors, Dr. Tracci noted.

While her group at the University of Virginia is "in a position to do this" and maintains an EHR system that meets meaningful use requirements, she said, most practicing surgeons are in smaller groups, and will have a tougher time implementing EHR. And some practices have invested in EHR, only to find that the product they've chosen doesn't suit them and they need to switch. "That is incredibly costly, and also costly in terms of productivity," Dr. Tracci said.

Many enterprise-wide EHR products "are not well suited for subspecialty data requirements," noted Dr. Detmer. "When you get right down to it, when you put in an EHR, it's not about electronics, it's about changing the way you work. Once you make the transition -- and it usually takes a couple of months -- most folks would rather not go back."

The ACS is getting more engaged in an effort to help surgeons cope with the deadlines, he added. Surgeons who haven't started on any of these programs first should carefully analyze the reporting periods for all of the incentives and penalties when prioritizing which program to begin first, according to information provided by the ACS health policy division. "For example, this is the last year you can begin the stage 1 of the EHR incentive program to be eligible to receive the full incentive bonus of $44,000. The first 6 months of the year is also one of the reporting periods to avoid getting the 2013 eRx payment penalty," according to the ACS.

The time and money involved also should play a role in decision making. Keep in mind that the eRx and PQRS programs both have relatively low start-up costs, and do not take a long time to begin.

More Information

The ACS provides information focused on each quality program -- eRx, HER, and PQRS -- where surgeons can find resources such as flow charts and step-by-step guides to help lead them through the process of implementation:

-- ACS Division of Advocacy and Health Policy: www.facs.org/ahp/index.html

-- EHR: www.facs.org/ahp/ehr/index.html

-- eRx: www.facs.org/ahp/erx.html; www.facs.org/ahp/erx-exemption.pdf

-- PQRS: www.facs.org/ahp/pqri/index.html

However, "if you get into this, you will need to have someone in your group really spend some time with it," Dr. Detmer cautioned. In addition, he noted that there can be long waits for installation of popular products, which surgeons need to keep in mind while considering when the EHRs need to be operational to avoid CMS penalties.

In general, institutions are much further ahead on EHRs than are surgeons practicing solo or in small groups, Dr. Detmer said. "Most people who are in an institution or large system are typically well into this at this point," he said. "If they haven't made the move to [electronic] order entry, they're doing it right now."

In institution-wide efforts involving multiple specialties, "surgeons don't necessarily have to lead, but surgeons will need a champion as part of the process," he added.

With the new subspecialty certification in medical informatics now available, "there really is a need for some young surgeons to decide they need to be part surgeon, part informatician," Dr. Detmer said. "We have some good surgeons involved in this, but not the numbers we need."

The incentives offered for early adopters of the various electronic health initiatives promulgated by the Centers for Medicare and Medicaid Services are expected to transition into penalties within the next 2-3 years.

Currently, the Electronic Prescribing, or eRx, program offers both incentives and penalties. However, the Electronic Health Record (EHR) and Physician Quality Reporting System (PQRS) programs, which still offer incentives for participating, will transition to penalties by 2015.

The EHR incentive program authorized up to $27 billion for incentive payments to hospitals and physicians for "meaningful use" of a qualified electronic health record. Surgeons and other physicians qualifying for the first time last year and this year could receive up to $18,000 in the first year and annual payments through 2016 totaling $44,000.

During 2013 and 2014, there will be a reduced incentive for initial qualification, and beginning in 2015, failure to demonstrate meaningful use will lead to a penalty of 1% in Medicare reimbursement. That penalty increases to 2% in 2016 and to 3% for 2017 and beyond.

Dr. Margaret Tracci, a vascular surgeon at the University of Virginia Health System who has analyzed these programs and their potential effects on surgeons, projects that penalties for surgeons who don't meet the requirements for any of the programs could reach 5.5% in 2018.

The overall emphasis on primary care in the initial program rollouts may have made surgeons less attuned to the concept of electronic reporting and record-keeping, according to Dr. Don Detmer, medical director of the American College of Surgeons (ACS) Division of Advocacy and Health Policy. "It let some surgeons think they could put it off," he said in an interview. "We started out with some carrots, but the carrots are becoming sticks. Still, it's not like this hasn't been known from the beginning."

Ways to Participate

The ACS doesn't have a good sense of how many surgeons and which types of practices aren't prepared for these programs to transition to penalties. Nonetheless, EHR adoption may have outpaced adoption of the PQRS and eRx, because many surgeons are using some form of electronic health record, according to Dr. Tracci. There's less participation in electronic prescribing programs or in PQRS as of yet, she said.

PQRS, which began in 2007 as an incentive program for voluntary reporting of quality measures, will transition into penalties for nonparticipants beginning in 2015. Surgeons who don't report data for PQRS will be hit by a 1.5% Medicare reimbursement penalty in 2015 and a 2% penalty in 2016. Conversely, there's a 0.5% incentive available for Maintenance of Certification (MOC) for those who participate in PQRS through a qualified entity.

Surgeons and other "individual eligible professionals" may report selected measures by several mechanisms, including claims-based, registry-based, or EHR-based mechanisms. There's also a group practice reporting option, although the deadline already has passed for groups to select this option.

For PQRS, "there are three registries surgeons can use to participate now [but] we really are on our own collecting and submitting data," Dr. Tracci said. Several hundred institutions nationwide have formed their own registries, she added.

A 2009 CMS report indicated that surgeons are far more likely to report PQRS data when they participate in their own group's registry. However, there are no recent data indicating just how many surgeons are participating, according to the ACS.

The electronic prescribing, or eRx, incentive program provides an incentive to use a qualifying electronic health record to generate and transmit eligible prescriptions for Medicare beneficiaries. This program begins transitioning to its penalty phase this year.

To avoid penalties, individuals and groups must generate a set amount of e-prescriptions. "In practice, it has been much harder for surgeons to meet the requirements than primary care physicians," said Dr. Tracci.

Pay Now or Pay Later

EHR programs are admittedly expensive to implement, but the penalties for failing to do so can add up into the millions over the life of the program for a physician group of several hundred surgeons and other doctors, Dr. Tracci noted.

While her group at the University of Virginia is "in a position to do this" and maintains an EHR system that meets meaningful use requirements, she said, most practicing surgeons are in smaller groups, and will have a tougher time implementing EHR. And some practices have invested in EHR, only to find that the product they've chosen doesn't suit them and they need to switch. "That is incredibly costly, and also costly in terms of productivity," Dr. Tracci said.

Many enterprise-wide EHR products "are not well suited for subspecialty data requirements," noted Dr. Detmer. "When you get right down to it, when you put in an EHR, it's not about electronics, it's about changing the way you work. Once you make the transition -- and it usually takes a couple of months -- most folks would rather not go back."

The ACS is getting more engaged in an effort to help surgeons cope with the deadlines, he added. Surgeons who haven't started on any of these programs first should carefully analyze the reporting periods for all of the incentives and penalties when prioritizing which program to begin first, according to information provided by the ACS health policy division. "For example, this is the last year you can begin the stage 1 of the EHR incentive program to be eligible to receive the full incentive bonus of $44,000. The first 6 months of the year is also one of the reporting periods to avoid getting the 2013 eRx payment penalty," according to the ACS.

The time and money involved also should play a role in decision making. Keep in mind that the eRx and PQRS programs both have relatively low start-up costs, and do not take a long time to begin.

More Information

The ACS provides information focused on each quality program -- eRx, HER, and PQRS -- where surgeons can find resources such as flow charts and step-by-step guides to help lead them through the process of implementation:

-- ACS Division of Advocacy and Health Policy: www.facs.org/ahp/index.html

-- EHR: www.facs.org/ahp/ehr/index.html

-- eRx: www.facs.org/ahp/erx.html; www.facs.org/ahp/erx-exemption.pdf

-- PQRS: www.facs.org/ahp/pqri/index.html

However, "if you get into this, you will need to have someone in your group really spend some time with it," Dr. Detmer cautioned. In addition, he noted that there can be long waits for installation of popular products, which surgeons need to keep in mind while considering when the EHRs need to be operational to avoid CMS penalties.

In general, institutions are much further ahead on EHRs than are surgeons practicing solo or in small groups, Dr. Detmer said. "Most people who are in an institution or large system are typically well into this at this point," he said. "If they haven't made the move to [electronic] order entry, they're doing it right now."

In institution-wide efforts involving multiple specialties, "surgeons don't necessarily have to lead, but surgeons will need a champion as part of the process," he added.

With the new subspecialty certification in medical informatics now available, "there really is a need for some young surgeons to decide they need to be part surgeon, part informatician," Dr. Detmer said. "We have some good surgeons involved in this, but not the numbers we need."