Stage 2: The Delay Dilemma

In the last few weeks multiple professional organizations have called for some form of extension for  Stage 2 of the EHR Meaningful Use program. While the general theme is “delay,” the specific recommendations have varied:

MGMA – Requests that HHS extends the reporting period for Stage 2 incentives for a minimum of one year. MGMA also calls for a moratorium on penalties for providers that have completed Stage 1 requirements.

AAFP – Proposes three distinct “cohorts” of EPs, each with a different schedule depending on what year they first attested for MU. The timeline would require vendors to be ready for Stage 2 by January 1, 2014 but extend the implementation period from nine months to 21 months, depending on the cohort.

CHIME – Calls for a one year delay for implementation of Stage 2.

AMA/AHA – In a joint letter to HHS Secretary Kathleen Sebelius, the associations call for providers at Stage 1 to meet MU requirements for Stage 2 using either a 2011 or the 2014-certified EHR; the establishment of a 90-day reporting period for the first year of each new stage of MU; more flexibility in meeting Stage 2; and, an extension for each stage of no less than three years for all providers.

HIMSS – Recommends Stage 2 start as scheduled but that the attestation period  be extended through April 2015 for EHs and June 2015 for EPs. Providers would have 18 months to  attest to quarterly MU requirements.

One theme that is consistent from all the organizations is that the delay is necessary because vendors need more time to prepare and certify the required software upgrades and because providers need additional time to implement and optimize their EHR technology.

I must admit that when the various associations and industry leaders first began rumbling about a delay, my first thought was, “You’ve got to be kidding!” Lest anyone forget, HHS already extended the Stage 2 deadline once in November, 2011. By delaying again, HHS would be repeating its long history of telling vendors and providers that deadlines are made to be broken.

Regardless, there now seems to be a groundswell of sentiment in favor of a Stage 2 delay. No one at HHS, including Secretary Sebellius or the soon-to-be-departing Farzad Mostashari, has indicated that a postponement may happen, though my money is on policymakers agreeing to an extension for meeting and reporting on Stage 2 requirements and for delaying penalties for providers that have met Stage 1. I would hope that the January 1, 2014 start date remains intact.

Why? Maintaining the original start date means vendors must continue moving forward to ready their products. If the start date were also delayed, software release dates would undoubtedly be pushed and providers could again find themselves without adequate time to fully test, train, and implement the required updates and make any necessary changes to workflow. Keeping the original date also means early adopters would have the opportunity to attest early in 2014 and thus be paid their MU incentives.

Readers, I’d love to hear your thoughts on the possibility of a Stage 2 delay and how that delay might look.

Email Inga.