Earlier this year the Health IT Policy Committee published a proposal for potential Stage 2 meaningful use objectives and solicited public comment regarding the same. We reviewed the proposal in an earlier post. Then, we and over 400 entities, including other members of the renal community, commented on these objectives. Last month, during their regularly scheduled meeting, the Health IT Policy Committee summarized the comments they received. From a timing perspective we can expect to see their final recommendations for Stage 2 sometime during June of this year. In the 4th quarter of this year we should see a notice of proposed rule making (NPRM) from CMS related to Stage 2, with the final rule to be published by HHS in first or second quarter of 2012.
Of interest, during last month’s meeting, the Health IT Policy Committee contemplated several options that would impact the implementation of the Stage 2 meaningful use objectives. The press quickly latched on to one of these—delaying Stage 2 by one year. But, in fact, the committee discussed four possible strategies during the meeting:
1. Maintain the existing timeline implementing Stage 2 in 2013.
2. Maintain the existing timeline but reduce the reporting period for the first year of Stage 2 to any continuous 90-day period as it is for Stage 1.
3. Postpone the entirety of Stage 2 until 2014 (a one-year delay).
4. Create a phased approach:
a. Phase 2a—Rollout the increased Stage 1 targets in 2013.
b. Phase 2b—Rollout the new Stage 2 objectives in 2014.
During their meeting on May 11, options 1–3 above remained on the table.
What would be the impact of a one-year delay in the Stage 2 objectives? In large part the answer depends on perspective. For EHR vendors, any delay in Stage 2 would be seen as beneficial as the vendors would have more time to develop, test and deploy the Stage 2 objectives.
What about the practicing nephrologist? How would a delay in the Stage 2 objectives impact this group? As pointed out by Dr. Paul Tang in the article referenced above, postponing the Stage 2 objectives by one year would only impact earlier adopters—those providers who attest to meaningful use in 2011. If Stage 2 is delayed one year, Dr. Tang points out that, “Because of the way the rule is written, those people would be subject to a loss of one year’s incentive.” This is related to the fact that providers will report the Stage 1 objectives for 2 years and skipping a year results in loss of an incentive. What’s the price tag these early adopters would face? It is the potential loss of the incentive for reporting in year 3 ($8,000 per provider). This would only impact those electing to report under the Medicare path, but in my estimation this represents the majority of nephrologists. With the exception of providing an additional year to adopt the changes made by EHR vendors, little would change for the remainder of the eligible professionals across the country by delaying the Stage 2 objectives.
The Health IT Policy Committee is expected to make its final recommendations for Stage 2 to ONC and CMS next month. In the interim we would like to know what you think about the committee’s proposal to delay Stage 2. Post your comment below; we look forward to hearing from you.
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