The HIT Policy Committee (HITPC) convened their June meeting last Wednesday. The first three hours of the meeting were devoted to a discussion of the recommendations they plan to forward to ONC and CMS regarding proposed Stage 2 meaningful use objectives as well as the timing of implementing these objectives. The objectives themselves will be reviewed at a later date on this blog, but a summary of the recommended Stage 2 objectives may be found on the ONC website.
On our plate for discussion today is HITPC’s recommendation that the Stage 2 objectives be delayed by one year. Recently on this blog I reviewed what I anticipated would be a detrimental financial consequence of such a delay upon early adopters—providers demonstrating meaningful use in 2011. In retrospect my interpretation of Paul Tang’s comments was not correct. Today I will set the record straight. The delay in Stage 2 does not convey a financial penalty upon early adopters.
Why Delay Stage 2?
First, a bit of background surrounding the proposed delay. The HITPC recognized an unanticipated timing problem that would adversely impact EHR vendors and early adopters. Without a delay in the Stage 2 objectives, the following scenario would play out. The final rule for Stage 2 would be published mid-2012. Vendors would scramble to develop and deploy the required feature functionality, then arrange to certify their technology with an ONC-ATCB. Subsequently, customers would be expected to implement and adopt these changes in preparation to demonstrate meaningful use.
The provider burden in the above scenario falls squarely on the early adopters’ shoulders. As an early adopter, I would demonstrate meaningful use with the Stage 1 objectives in 2011 and 2012. At some point near the end of 2012 I would switch gears to the Stage 2 objectives, hoping my vendor certified my EHR in time, and try to bring my practice up to speed so I could begin capturing Stage 2 data as of January 1, 2013. Notice hospitals are even further up the creek as their reporting years are tied to fiscal years; so the early adopter hospitals would need to begin capturing Stage 2 objective data as of October 1, 2012.
The Proposed Solution
HITPC recognized the above scenario was untenable for both vendors and early adopters and they entertained a variety of solutions. At their meeting on June 8 they voted 12 to 5 in favor of postponing the implementation of the Stage 2 objectives until 2014. From the providers’ perspective this will only impact the early adopters—those providers demonstrating meaningful use this year as demonstrated in the table below:
What has been further clarified since I last wrote about this topic is that a one-year delay in the Stage 2 objectives will not create a financial burden on the providers. In fact, one might argue the contrary. Note in the above table that the early adopters are the only providers who will base meaningful use demonstration on the Stage 1 objectives for three years. All other providers must report the Stage 2 objectives in their 3rd year of reporting.
The Downside
Is there any risk in delaying the Stage 2 objectives? There were a couple of concerns expressed during the Committee’s meeting last week. One concern was that the delay might send the wrong message to patients. Another concern that received a substantial amount of discussion during the meeting revolved around the impact a delay in Stage 2 might have on compressing the Stage 3 timeline. At the end of the day the majority of the members of the HIT Policy Committee agreed the benefits of a delay were well worth the risks.
Next Steps
HITPC has forwarded their proposed Stage 2 objectives and their proposal to delay Stage 2 until 2014 to ONC and CMS. It is anticipated CMS will generate a notice of proposed rule making (NPRM) for the Stage 2 objectives in the 4th quarter of this year. Following a 60-day comment period, CMS will analyze the public comment they received and publish the final rule for Stage 2 in mid-2012. What are your thoughts regarding the proposed delay in Stage 2? How do you foresee it will impact your practice’s drive towards meaningful use? We’d love to hear your comments.
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