CMS proposes Stage 2 extension--no delay

The Centers for Medicare & Medicaid Services (CMS) has proposed a new timeline for the implementation of Meaningful Use (MU) for the Medicare and Medicaid EHR Incentive Programs and the Office of the National Coordinator for Health Information Technology (ONC) proposed a more regular approach to update its certification regulations.

Under the revised timeline, Stage 2 will be extended through 2016 and Stage 3 will begin in 2017 for those providers that have completed at least two years in Stage 2. According to the CMS announcement, 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 in Stage 2; and second, to utilize data from Stage 2 participation to inform policy decisions for Stage 3.

This new timeline isn’t quite the change major industry advocacy groups were hoping for and have been seeking. “They haven’t given us any flexibility to the start of Stage 2 which is what we’ve been requesting, said Russ Branzell, CEO of the College of Healthcare Information Management Executives (CHIME) in an interview with Clinical Innovation + Technology.

The timeline change offers no relief in the start of Stage 2, Branzell said. “I appreciate the effort they’ve made—it will provide some help in Stage 3. But, with the emergence of so many different initiatives, including security, Meaningful Use, ICD-10, and the Affordable Care Act, all emerging at mid to later next year, too many things are coming at one time.”

CHIME reiterates its belief that some providers will need an additional year to install, test, implement and operationalize the new certified EHR software, according to the organization's release on the subject.

The change is more beneficial for the vendor community, says Laura Kreofsky, principal advisor at Impact Advisors, a health IT consulting firm. In fact, “in many respects, [this change] helps CMS prepare more than the provider community.” The change has no impact on the implementation timeframe of Stage 2, she said, and “the pain we’re feeling as providers is not because of Stage 3. We’re in the throes of Stage 2.”

There’s reason to be concerned that people will be confused about what this announcement really means, said both Kreofsky and Branzell. Providers might think that what professional associations have been asking for is what has happened and that is not the case, Branzell said.

“The language of the {CMS announcement] is not very clear,” adds Kreofsky. Providers need to stay focused on what they need to do for 2014 regardless of the stage they’re in. “I think we’re going to run into a place where a lot of providers are confused about what’s coming out when, what’s voluntary and what’s standard, and what’s in the proposed rule and what’s in the final rule. Providers are overwhelmed by what’s going on.”

If the proposed rule does come out next fall, she said stakeholders could be distracted by ICD-10 implementation and not give it the focus needed during the allotted review and feedback timeframe. At the same time, providers will be faced with ONC’s 2015 voluntary criteria. “It feels like it’s becoming very onerous just to understand the moving parts and pieces and parallel tracks between certified EHRs and meaningful use of those certified EHRs.”

It’s also important for providers to know, Kreofsky said, that this timeline change does not include any breaks from incentives or penalties in the long- or short-term.

In its announcement, CMS said the proposed timeline offers the following benefits:

• More analysis of feedback from stakeholders on Stage 2 progress and outcomes;
• More available data on Stage 2 adoption and measure calculations – especially on new patient engagement measures and health information exchange objectives;
• More consideration of potential Stage 3 requirements;
• Additional time for preparation for enhanced Stage 3 requirements;
• Ample time for developers to create and distribute certified EHR technology before Stage 3 begins, and incorporate lessons learned about usability and customization.

There are still opportunities “for us to get some flexibility,” said Branzell. CHIME will continue to advocate for providers, he said. “I’m still optimistic but it’s going to take some work.”

Read the entire CMS announcement here.