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As announced by the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health IT (ONC) on December 6, Stage 2 of Meaningful Use will be extended for an additional year. Stage 3 of the government EHR Incentive Program will begin in 2017 for eligible professionals (EPs) who have performed at least two years of Stage 2.
Per CMS officials, the duration of the reporting period for the first year of Stage 3 will be clarified in the Stage 3 rule-making. The complementary 2017 Edition Certification and Stage 3 Meaningful Use notice of proposed rule-makings (NPRMs) will be issued in fall 2014 for public comment and the respective final rules will be issued in summer 2015.
There has been a lot of confusion around this issue, so it is important to remember that this programmatic update does not mean that the first, quarter-long reporting period for Stage 2 will be delayed past January 1, 2014 for EPs.
It is also important to note that the extension of Stage 2 does not affect payment adjustments for providers. The same payment adjustments apply on the same schedule. The extension simply adds an extra year of Stage 2 performance so that those providers who begin Stage 2 in 2014 will perform Stage 2 for three years. All other providers will follow the same schedule of performing Stage 2 for two years before beginning Stage 3.
Clinical Quality Measures (CQMs) will continue to be clarified by CMS and defined by the Meaningful Use rule. We can expect continued efforts to align quality measures across government programs and updates to quality measurement as part of other initiatives, such as the Medicare Physician Fee Schedule rule and other payment models.
The 2014 Edition will now be valid through 2016 for certified EHR technology. Of note, there will be a 2015 Edition certification criteria that is voluntary for both vendors and providers. The certification criteria for this edition will include additions and updates to existing criteria to serve providers participating in other government programs while also remaining supportive of providers fulfilling Stage 1 and Stage 2 requirements.
In a call on December 6, the ONC communicated their intent for this 2015 Edition to enable a faster certification process by allowing the agency to issue incremental rule-making to allow vendors to prepare for future requirements and implement criteria iteratively. The ONC also explicitly called out the difference between the Meaningful Use program and certification. Case in point: the 2015 Edition certification criteria will not be accompanied by Stage 3 Meaningful Use requirements.
Despite the introduction of the 2015 Edition, the 2014 Edition will remain the baseline for Meaningful Use until the 2017 Edition. The 2015 Edition proposed rule is planned for release in February 2013 and the 2015 Edition final rule is targeted for release in summer 2014.
This clear delineation signals ONC plans to expand the scope of certification to apply to other government initiatives, in addition to the EHR Incentive Program. Given the broad definition of health IT, medical mobile application, consumer health, and other health IT developers may also find themselves in a position to certify to ONC certification criteria.
Impact of Extension
Most EPs, eligible hospitals, and critical access hospitals will benefit from gaining an extra year to plan for Stage 3 and adopt the next wave of certified technology. With more time prior to the next certification edition, some vendors will capitalize on the extra time to focus development efforts on innovations outside of the government program. Finally, policymakers now have more time to learn from Stage 2 implementation and continued collaboration with industry.
Additionally, with efforts underway to reform physician reimbursement, the extension of Stage 2 will give policymakers the ability to better align Stage 3 with important macro-level changes in healthcare.
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