December 10, 2013
Late Friday afternoon, the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health IT (ONC) jointly announced some timeline changes for stages 2 and 3 of meaningful use. Stage 2 will be extended one year, pushing the start date for stage 3 back to 2017. Providers will have an extra year to meet stage 2 requirements, just like they did with stage 1.
According to the ONC’s Health IT Buzz blog post, “The goal of this change is two-fold: first, to allow CMS and ONC to focus efforts on the successful implementation of the enhanced patient engagement, interoperability and health information exchange requirements for Stage 2; and second, to utilize data from Stage 2 participation to inform policy decisions for Stage 3.”
There is still some confusion regarding how the timeline changes will affect providers, though.
2014: No change
At first glance, it may seem like CMS has given providers an extra year to prepare for stage 2, something physician groups have been advocating for a while now, but that is not the case. Providers have an extra year to meet stage 2 requirements, yes, but it still begins in 2014 as planned. Those who have attested for two years on stage 1 will have to move to stage 2 next year.
Since providers are only required to attest to stage 2 for two years before moving on to stage 3, and now that stage 2 encompasses three years instead of two, does that mean providers will need to shoot for “best two out of three” attestation during that time period? Doubtful. Most likely providers will have to meet stage 2 until stage 3 starts, even if it means they attest to stage 2 for three years. That would follow the precedent the government has already set for stage 1.
Even though the timeline changes won’t affect providers’ preparations for 2014, most are grateful for the extension. Three years per meaningful use stage seems to accommodate providers and vendors much better than two years per stage.
2015 and beyond: More time, better regulations
It’s stage 3 that will be most affected by the timeline changes. With an extra year to put together a final rule for stage 3, policymakers will be more able to adequately assess stage 1 and stage 2 successes and failures and plan stage 3 accordingly.
In addition, EHR vendors will have the option of re-certifying their products to the voluntary 2015 Edition. Most vendors are still in the process of re-certifying for 2014, so voluntary 2015 certification is the farthest thing from their minds. However, the 2015 Edition would aim to address issues found in the 2014 Edition, incorporate appropriate stakeholder feedback, and update standards as interoperability becomes more of a reality.
From the beginning, CMS/ONC has tried to keep the meaningful use program smart and aggressive. The original timelines turned out to be too aggressive, so many are applauding CMS for recognizing that and adjusting timelines as we go along. This will allow more practices and hospitals to meet government requirements and avoid penalties.
2014 is shaping up to be a difficult year, regardless. Meaningful use, ICD-10, HIPAA, and accountable care organizations are all clamoring for providers’ attention. With no plans to delay any government health IT initiatives, the government is reminding providers to keeps their eyes on long-term goals, in addition to short-term ones. “The fact that [this] announcement did not address 2014 issues does not imply that no one is listening to those concerns,” said John Halamka, CIO of Beth Israel Deaconess Medical Center and co-chair of the HIT Standards Committee. “Some may complain that they were expecting lunch and dinner but only got lunch. It’s fair to say that lunch comes before dinner.”