While it is by no means certain the group will take such action, comments by Paul Tang, M.D., VP and CMIO at Palo Alto Medical Foundation and chair of the Meaningful Use workgroup, indicated he was interested in exploring all options.
Distilling the public comments, Joshua Seidman, acting director of the Meaningful Use Division in ONC's Office of Provider Adoption Support, said, "The steepness of the curve, in terms of the upward movement raising the bar, and timeline," were expressed as problematic. "There were concerns about the timing, in terms of providers and vendors being able to get systems ready. So if there are new functionalities that must be put in place, and the final rule comes out in mid-2012 as HHS has indicated, how much time does that allow for implementation of those functionalities?"
Seidman said some comments recommended that enough time be built into the process so ONC could inject Stage 1 lessons learned into Stage 2.
Another group of letters stated that some Stage 2 measures lacked sufficient specificity for informed commenting, and asked that more detail be added before the proposals could be properly evaluated.
Seidman said not all comments urged caution. Some, in fact, asked that the program's momentum continue apace.
Before exploring options for dealing with the timing issue, Tang set the table by reviewing those elements of the program that were baked into statue and, thus, not subject to ONC or CMS modification. He noted, for example, the program's penalties constituted an incentive toward compliance in the out-years, somewhat offsetting the fact that the lion's share of incentive money is heavily front-loaded. Nonetheless, he expressed concern with pushing too many Meaningful Use objectives into the future.
But a desire to keep Stage 2 as robust as it currently is may be difficult, given the ripple effects associated with adding measures not supported by current software. "There is the required vendor-development time and provider implementation and training time, both of which are sizeable and significant. They must be done in sequence, they are additive," Tang said.
Not all MU requirements, however, would require vendors to change their code and, thus, be recertified. In measures that only called for increasing current thresholds or tapping dormant functionality already embedded in products, the timelines required for compliance would be vastly reduced.
In addition to tempering requirements, Tang suggested ways the timeline could be adjusted.
In one scenario, he suggested it was possible to change the Stage 2 reporting period from a full year to 90 days (like Stage 1). "That would give a nine-month grace period to get all downstream things accomplished before you have to be operational with a fully certified Stage 2 HER -- that's one way to give some relief on timing," he said.
Another option, Tang said, was to delay Stage 2 altogether, perhaps 12 months; while a third option (one recommended by CHIME) could be to delay Stage 2 until a certain percentage of hospitals and eligible providers achieved Stage 1.
Such solutions, Tang said, were not without their drawbacks. "A consequence of [delay] is that all this supports health reform and, as ACO rules come out, providers are going to need an EHR with much functionality around exchange and care coordination, so to delay Stage 2 would hurt the whole [healthcare reform] program," he said.
The workgroup's next meeting will be an in-person event on April 5, when it will "go through a list of criteria on the Stage 2 goals and somehow incorporate a timeline discussion." The workgroup will then present its recommendations to the full HIT Policy Committee on April 13. On May 2, Tang said the workgroup would convene to discuss the feedback it had received from the Policy Committee, refining its Stage 2 proposals. On May 11, the workgroup will present its Stage 2 "package" to the Policy Committee for a second review. "We will then finalize our proposal after that meeting in preparation for a presentation at the June 8 Policy Committee meeting when we will ask for approval."