As signaled to InformationWeek Healthcare by CMS official Rob Tagalicod in September, the Centers for Medicare and Medicaid Services (CMS) has proposed extending the period for attesting to Meaningful Use stage 2 through 2016. Some in the industry welcome the one-year extension, which will give providers and vendors more time to prepare for Meaningful Use stage 3. But the associations that represent health IT professionals view the policy change as grossly inadequate.
Both the College of Health Information Management Executives and the Healthcare Information Management and Systems Society (HIMSS) pressed CMS to give providers additional time to meet the Meaningful Use requirements on the front end. Although they're not asking for a delay in the official start dates of stage 2 -- Oct. 1, 2013 for hospitals and Jan 1, 2014 for eligible professionals -- they want CMS to give providers between 18 months and two years to meet the requirements and still be eligible for 2014 incentives.
This flexibility is also needed, the associations say, because many hospitals have not yet received updated software and because they must deal with a number of other priorities in 2014, notably the transition to the ICD-10 coding system.
"There is a perfect storm brewing," said Russ Branzell, CHIME’s CEO, in a statement:
With ICD-10 compliance coming into view, with HIPAA compliance demanding renewed attention and with all the activities associated with the Affordable Care Act converging in 2014, providers are nearing a breaking point. Flexibility of the kind announced today is beneficial for Stage 3, but Stage 2 start-date flexibility is needed to ensure long-term success.
In a blog post last Friday, Jacob Reider, acting national coordinator for health IT and Tagalicod, director of the office of e-health standards and services at CMS, explained the agency's policy change:
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. The goal of this change is two-fold: first, to allow CMS and ONC [Office of the National Coordinator for Health Information Technology] 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.
The officials said that the proposed change would give the government more time to analyze feedback from stakeholders on stage 2 progress and outcomes and consider potential stage 3 requirements. Providers would have more time to prepare for stage 3, and vendors would have additional time to rewrite their software and distribute it to customers in advance of stage 3.
That's all very fine, Branzell told InformationWeek Healthcare, but it doesn't really help the CIOs who will have to deal with the myriad demands on their time and resources next year. Moreover, he noted, there's a financial penalty for hospitals that are unable to complete the 90-day attestation to Meaningful Use in 2014.
"We want flexibility for organizations to not necessarily apply in 2014 and suffer a year of loss of the incentives," he said. "If they took 2014 off, they'd just lose that year and then would have to pick up the next year -- if they ever picked up."
One reason why providers are between a rock and a hard place is that many vendors either have just gotten their EHRs certified for 2014 or have not yet had them certified. A recent HIMSS Analytics survey found that 72% of hospitals and 44% of hospital-affiliated ambulatory facilities had purchased 2014-certified EHRs. But Branzell noted, "Purchasing the software is significantly different than getting the software, installing it, testing it, changing your workflows, mapping all your data, and getting everything done that needs to be done to start that ticker going [on attestation to Meaningful Use]."
Moreover, he added, many providers have been told that they'll need additional patches and upgrades to their certified EHRs before they can use the system. With all of these challenges to getting the new systems up and running, even some of the larger healthcare organizations are saying they can't handle the challenge of MU stage 2 and ICD-10 in the same year, he said.
As a result, CHIME told Health and Human Services Secretary Kathleen Sebelius in a letter, "Numerous providers have already indicated that they will not pursue Meaningful Use stage 2 in 2014." Although Branzell couldn't tell us how many organizations fall into that category, he said, "It's a substantial enough number of providers that it will be disruptive to the industry."
The blog post about the stage 2 extension proposal noted that CMS expects to release its notice of proposed rulemaking (NPRM) for stage 3 in fall of 2014. Simultaneously, ONC is expected to issue an NPRM for the 2017 edition of its EHR standards and certification criteria.
The downside of this approach, Branzell said, is that CIOs won't know what to expect in stage 3 for nearly another year. "It would be nice to know what's coming out in stage 3 so we can time things effectively for what we might see in quality measures or new workflow requirements, those kinds of things," he said.
ONC is also proposing a 2015 edition of its certification criteria that would incorporate stakeholder feedback to improve on the 2014 requirements. Recertification based on the 2015 criteria would be voluntary for vendors, and providers would not have to use EHRs that meet those requirements to attest to Meaningful Use, according to the post.
Branzell isn't so sure it would work that way. "It won't necessarily be voluntary for providers, because at that point they'll be forced to take that update to get the latest software they need," he pointed out. "If you need a fix for a particular problem, the vendor might say, 'You have to take the 2015 update to get that fix.' Which we'd be very concerned about."
Branzell believes that CMS might still be willing to provide more flexibility in the timing of MU stage 2. He notes that the agency did something similar in stage 1, when it postponed the deadline for initial attestation by a year, allowing organizations to attest in either 2011 or 2012 for full credit.
Robin Raiford, a senior research director for the Advisory Board Co., said that CMS made this policy change primarily to signal to the industry that it wanted to incorporate the experience gained in Meaningful Use stage 2 before deciding how high to set the bar in stage 3. "CMS was saying, 'We're not going to rush this development for stage 3. We're making sure what's happening in stage 2 before we give you what stage 3 is.' "
Vendors will probably benefit more from this rule change than providers will, she added. While hospitals and doctors are mainly worried about attesting in stage 2, vendors are concerned about whether they're going to have enough time to get certified for stage 3. Without this rule change, she said, the vendors would end up in the same time crunch in 2015 that they're facing right now.
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