"There already is talk about the market weaning itself [from Meaningful Use]," he said in an interview with InformationWeek Healthcare. "There are some vendors who are saying that 'we're leaving the market: we support Meaningful Use stage 1, but we're not ready to support stage 2.' So the question between us and ONC [Office of the National Coordinator for Health IT], which oversees EHR certification, is where will the gaps be. We're looking at that situation now."
CMS has also been hearing from healthcare providers who say their vendors are not going to be ready for stage 2 in January, Tagalicod added. Right now, the agency is trying to determine how big a problem this is likely to be.
[ The American College of Physicians is also pushing back on the MU timeline. Read more at Doctors Propose 5 Changes To Meaningful Use Guidelines. ]
Assuming that it may be a problem, CMS officials are already discussing what to do about it. "There has been talk about extending -- and do we have the authority -- in terms of extending reporting periods for stage 2," Tagalicod said. "I wouldn't say that's under consideration, but it's one of the options we need to look at as we gather more information. The idea is to extend reporting periods so vendors have time to get to stage 2 from stage 1."
The reason that CMS would contemplate this kind of flexibility for vendors, he explained, is to ensure that there will be no negative effect to providers, or more importantly, to consumers.
Tagalicod would not specify what kinds of changes he was referring to, aside from noting that "different cohorts" might need different kinds of help. Currently, Medicare-eligible professionals beyond their first year of Meaningful Use must select a 90-day reporting period during 2014 to qualify for stage 2. They must attest to the data collected in that reporting period no later than Feb. 28, 2015.
Following a pilot of direct reporting of EHR-generated quality data to CMS this year for the Meaningful Use program and the Physician Quality Reporting System (PQRS), CMS in 2014 will begin accepting clinical quality data generated by EHRs for a 12-month period in lieu of attestation. But it's unclear whether CMS or most vendors are prepared for this.
According to Tagalicod, most major vendors are prepared, and CMS plans to work with smaller firms to get them ready for this transition. But is the agency itself ready to accept and normalize the data from all of these disparate systems?
"We're prepping our system to accept 'big data' and to do it increasingly in a more timely manner," Tagalicod said. "The question for us is whether we can do that in real time and with the kind of analytics we've been talking about, and that's a decision that's being made. So the answer is yes, based on the resources and risks within our agency."
Another challenge for CMS is to align the clinical quality measures for Meaningful Use with those of PQRS, the Medicare Shared Savings Program for accountable care organizations, and the CMS value-based purchasing program. In a current pilot, for example, eligible professionals report on a single set of measures for both PQRS and Meaningful Use.
Tagalicod said that CMS strongly supports this approach but is still determining whether it has statutory authority for it. "We're finding we have some latitude, so we're engaged in rulemaking to make sure we have better alignment [of clinical quality measures]," he said.
The CMS official also suggested that the deadline for health plans and providers to adopt the electronic funds transfer (EFT)/electronic remittance advice (ERA) operating rules, scheduled to go into effect Jan. 1, 2014, might not be written in stone. "We're still open to looking at [that], in light of the other things that lie ahead, such as Meaningful Use and ICD-10, and looking at our time frames."
Last January, CMS delayed the deadline for the operating rules for insurance eligibility and claims status data by three months because the industry wasn't ready.