A panel developing clinical and process measures for meaningful use endorsed the delay of stage 2 for one year until 2014. As a result, providers will have three years through 2013 in which to verify that they have met stage 1 meaningful use requirements.
The delay is designed to avoid the train wreck that probably would result from the publication of the final rule for stage 2 requirements just several months before the provider reporting period would begin. The timing revision will only affect those providers who have attested to stage 1 in 2011.
The delay is among the stage 2 recommendations that the Health IT Policy Committee approved at its meeting June 8 by an overwhelming vote of 12 to 5.
The original 2013 timeframe does not give vendors enough time to design, develop, and test new functionality and providers to deploy it and report measures for one year, said Dr. Paul Tang, vice chair of the Health IT Policy Committee and chair of its meaningful use work group.
“The only group that would be affected is the early entrants who qualify for stage 1 in 2011 who get put into a bit of predicament in an unintended way,” he said. Tang is also chief medical information officer at the Palo Alto Medical Foundation.
As a result, stage 1 demonstration and attestation would continue through 2013; stage 2 would start in 2014 and stage 3 in 2015. With the revised timing, providers will still receive the same payments as originally planned. Instead of 2013, however, early entrants will have to wait to attest and receive payments for stage 2 in 2014.
Some committee members have said delaying stage 2 will put a similar compressed timing pressure on stage 3 for vendors to ramp up design and development and providers to upgrade just one year later.
Tang said that the concerns of some members on the timing option and a lack of flexibility among some of the measures will be addressed in a preface to its letter of recommendations to the Office of the National Coordinator for Health IT and the Centers for Medicare and Medicaid Services.
CMS will have a year of feedback from the public before it finalizes the stage 2 rule in mid-2012 and the healthcare environment may look different then, Tang said.
“The world has changed even in the two years that we have been in existence,” he said. As members suggested, the committee could start communicating immediately with vendors about functions and features that could be required in stage 3 to get a head start on development, he said.
The meaningful use work group has extensively debated the timing issue and came to their decision by calculating the impact of timing options of maintaining the original 2013-2014 timeline with a one-year reporting period or preserve the original timeline but reduce reporting period to 90 days like stage 1.
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Among stage 2 meaningful use measures is an emphasis on care coordination that combine recording and providing summary of care records, which were an option in stage 1 but moved to core or a required measure. The recommendation adds requirements to provide a care plan that contains goals and patient instructions, identify the care team members, which as a floor is just the primary care provider where that exists, and, finally, to transmit electronically the care record and care plan.
Healthcare reform provides drivers to have the capability to obtain this information, including accountable care organizations and patient-centered medical homes, Tang said. “We want to make sure EHRs can capture and transmit this information. They cannot today. These requirements make that possible,” he said.