In a recent announcement, the Department of Health and Human Services (HHS) has postponed the start of Stage 2 Meaningful Use from its original 2013 start date, to 2014.
The criteria for what will be of expected of clinicians for Stage 2 Meaningful Use is still under review, and a finalized decision on this is expected in February 2012. For Stage 1, there are 25 criteria (15 core, 10 menu items from which a clinician must choose 5) needed for Attestation and access to incentive money. It is expected that Stage 2 will set the bar higher, with higher performance thresholds, and demonstration of actual clinical data exchange between local systems.
Given the timelines, that leaves a very short interval for EHR vendors to build the elements needed to satisfy Stage 2 criteria, and re-certify as Stage 2 Certified EHRs. Previously, the Office of the National Coordinator for Health IT (ONC) had postponed the process for Certification by a year, as we noted previously.
Besides building new versions of their EHRs to satisfy the new Stage 2 criteria, many traditional vendors (and their client hospitals, medical groups and physicians) will then face the time-lag (and cost) needed to upgrade their current installations to the new product – something that may take many months. Of course, that is not a hurdle for web-based products, since new versions can be distributed to everyone everywhere basically instantaneously.
Does this discourage early adopters?
The ONC is determined to encourage clinicians to adopt EHRs as soon as possible. The early adopters, who started their Attestation in 2011, therefore will get an additional year of being held to Stage 1 standards, according to the new HHS clarification.
The 2014 start date of Stage 2 will apply to everyone at the same time, meaning that 2011 adopters will be held to Stage 1 standards in 2011, 2012 and 2013, and start Stage 2 in 2014. Those who wait to start their Meaningful Use until 2012 will therefore be held to Stage 1 standards for 2012 and 2013 (2 years, rather than 3), and will start Stage 2 in 2014 also. Those who wait until 2013 will receive less money overall (there is a diminishing payout for the Medicare deployment of Meaningful Use), and will be Attesting to Stage 1 rules in 2013 but will need to ramp up to Stage 2 the next year, in 2014. And those who postpone starting until 2014 will start with Stage 2 from the beginning.
Meaningful Use meets real-life implementation challenges
It is encouraging to see that the ONC has remained open to comments from multiple stakeholders, and has modified their implementation schedule in response. At the same time, the transition to EHRs is something that, in our view, should be as wide and rapid as possible – American health care is measurably improved by having these modern tools at its disposal.
The difficulties in ramping up the technology, and its distribution, are largely a result of the traditional approach to local-enterprise EHRs (which has been part of the problem of low adoption in the first place). However, web-based and other (e.g. mobile) technologies are rapidly expanding, and EHR implementation using these new approaches, which has never been part of the mix (traditionally), is growing very quickly.
We encourage the ONC to focus on ways in which clinical data can be shared between clinicians, and to understand how web-based technologies “change the game” in this arena. Incorporating actual data sharing between clinicians (which may or may not be on the same system) is important for Stage 2, in our view. And continuing to reward clinicians for early adoption is certainly something that benefits everyone.