Monday was a big day for a lot of people, but particularly for those in health IT. In addition to it being tax day, the running of the Boston Marathon (coinciding with Patriots' Day in Massachusetts), and, at sunset, the beginning of Passover, Monday was also the first day healthcare providers were able to attest to meaningful use of electronic health records (EHRs) in order to earn Medicare subsidies for their technology purchases.

To qualify in their first year of participation in the incentive program, whether it is 2011 or 2012, hospitals and individual practitioners such as physicians must meet Centers for Medicare and Medicaid Services (CMS) standards for meaningful use for 90 consecutive days. Once providers believe they have satisfied that requirement, they may attest to meaningful use and apply for Medicare and/or Medicaid bonus payments through the newly activated system. (That site contains links to instructions on how to register and what information CMS requires, including a certification number for the EHR product being used.)

States may choose to administer meaningful use for providers qualifying for Medicaid bonuses. According to CMS, 13 states have opened registration, most recently Alabama and Missouri earlier this month.

While it may be tempting for providers to seek their extra funding as soon as possible, some believe it's best not to rush. Applying for bonuses in 2011 means a provider must achieve Stage 2 meaningful use in 2013 and Stage 3 in 2015, but hospitals and doctors can still earn the maximum subsidies even if they start Stage 1 in 2012.

"Once you start the process, then the clock is ticking, says Dr. Mitchell Morris, national leader for health IT at Deloitte Consulting and the Deloitte Center for Health Solutions. "You might as well wait a year."

For one thing, CMS has not finalized the standards for Stage 2 of meaningful use. Once that happens, EHR vendors must get their products re-certified to the new standards, which means customers likely will have to upgrade their software and learn some new processes. This step may be easy for large vendors of enterprise systems, but smaller EHR developers could struggle. "We've been getting bombarded by vendors to help them with certification," reported Morris, who previously was CIO of the University of Texas M.D. Anderson Cancer Center in Houston.

That does not mean that everyone should wait, though. "If you attest now, you'll have your cash by May," said Morris. "If you know you've got it nailed, if you've been doing this for years, hey, go for it," he added.

But even those who choose to delay should not stop working on their EHR projects. "I think waiting until 2012 is reasonable as long as people don't think you can slow down your implementation plans," Morris said.

Elizabeth West, a consultant with Health Technology Training Solutions, Tucson, Ariz., believes that the sentiment favoring waiting a year is waning. "Some of that caution has died down," said West, who has worked for numerous health IT vendors going back to the 1980s and is a former VP of the Healthcare Information and Management Systems Society (HIMSS). "Vendors generally are urging their customers to go ahead and apply [for the bonus money]."

West also believes that statements by the federal Office of the National Coordinator for Health Information Technology (ONC) present the possibility that the Department of Health and Human Services (HHS), which includes both ONC and CMS, could delay the start of Stage 2 for early filers. "ONC has been giving signals ... that they are going to deal with the time-frame issue," West said.

However, the general deadlines and incentive schedules are written into law by the 2009 American Recovery and Reinvestment Act. "Some of these things require a change in the law," Morris noted. In this political climate, expecting an extension could be a gamble. "The game of craps comes to mind," said Morris.

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