This past Friday evening as I was in the airport, delighted that my flight was departing on time in advance of the approaching winter storm, my phone began to chirp, signaling inbound email traffic. Settling into my seat on the plane I noticed the email counter steadily rising. What’s all the excitement about I wondered? The subject line said it all. CMS had delayed the third stage of the EHR Incentive program. An early Christmas gift from our good friends at the Agency? Well, not so fast.
ONC
Technically the announcement was made jointly by CMS and ONC. I mentioned a few weeks ago I had the opportunity to participate in a town hall style meeting with the ONC leadership while attending the annual AMIA meeting. These folks told us they were committed to marching forward with the meaningful use program. In fact when asked specifically about a delay, Jodi Daniel, director of ONC Office of Policy Planning stated such a delay was outside of ONCs control. “They (CMS) would have the authority to do that, but it would require a regulatory change.” Remarkable what can be accomplished in just a couple of weeks.
A history of delays?
Longtime readers of this blog may recognize a pattern. As you may recall, HHS delayed Stage 2 in a similar fashion. That delay was featured in this blog almost exactly two years ago. At the time, the Stage 2 delay created an advantage for early adopters. Providers starting the process in 2011 faced the Stage 1 objectives for three years, everyone else has two years of Stage 1 before graduating to Stage 2. That advantage is depicted in the table below, which is copied from the Stage 2 final rule.
Notice the first row of that table. Nephrologists who first demonstrate MU in 2011, faced the Stage 1 objectives in 2011, 2012 and this year. Those starting in 2012 or later face the Stage 1 objectives for two years; followed by the Stage 2 objectives for two years then the Stage 3 objectives for two years. I think you get the pattern.
Impact of the Stage 3 delay
So what does this all mean for the average nephrologist? Based on my read, you will see no direct impact for a few years. Take a look at the table below which represents my interpretation of what you can expect based on the announcement a few days ago. Note this has not been published by CMS; in fact we are unlikely to see this in print until the 2014 proposed physician fee schedule is available next summer. But there is a decent chance you will see something like this:
Notice the advantage of the delay again falls to the early adopters. If you started in 2011 or 2012, you will face the Stage 2 objectives for three years prior to graduating to Stage 3. For everyone else, it’s two years of Stage 2, then on to Stage 3.
Indirect Benefits
Delaying Stage 3 until 2017 should have an indirect benefit for everyone using an EHR. It permits your EHR vendor to get off the alternate year MU development treadmill and focus their efforts on things that you will find of greater value. That’s especially true for specialty-specific EHR vendors like Acumen. Postponing Stage 3 another year means our company is unlikely to run the certification gauntlet again until 2016. And that, quite frankly, is good news for every one of our customers!
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