KENTUCKY REGIONAL EXTENSION CENTER

MUStage2PicAs Meaningful Use Stage 2 approaches, many associations have voiced concerns over the strenuous pace of the Meaningful Use Incentive Program and offered recommendations for easing this burden.

Start On Time, Increase Attestation Period

Adopting an approach that encourages continued progress while simultaneously acknowledging short-term obstacles,Healthcare Information and Management Systems Society (HIMSS) recommends launching Stage 2 Meaningful Use on-schedule and extending Year 1 of the Meaningful Use Stage 2 attestation period through April 2015 and June 2015 for EHs and EPs, respectively. This would encompass 18 months in which EHs and EPs can attest to Meaningful Use requirements for one quarter.

“In our Call to Action, HIMSS asks the healthcare community – providers, hospitals and vendors – to come together in their execution plans for the 2014 certification process and implementation of 2014 certified products. We have recommended an extra six months to achieve Year 1 of Meaningful Use Stage 2, which is a brief amount of time when considering our ultimate and joint goal of successful implementation of health IT to support care coordination and healthcare transformation,” said Carla Smith, MA, CNM, FHIMSS, Executive Vice President, HIMSS.

Freeze Physician Meaningful Use Penalties

The Medical Group Management Association (MGMA) has called for a moratorium on meaningful use stage 2 penalties for physician practices that have attested to stage 1.

MGMA’s position stems from concerns over vendor readiness to provide upgrades and support in time to help practices avoid penalties in 2015. The letter states: “Even if a vendor does upgrade their product to meet the Stage 2 criteria and successfully certifies this product late in 2013 or sometime in 2014, these products must still be deployed to the client practices and staff trained on the new software and new Stage 2 reporting requirements.”

To combat the issue, MGMA recommends HHS extend both the stage 2 and stage 1 reporting periods to help practices avoid penalties, conduct a comprehensive vendor survey to assess readiness and build additional flexibility into the stage 2 reporting requirements.

Ease Meaningful Use Requirements

The American Hospital Association (AHA) and the American Medical Association (AMA) asked for greater flexibility in the requirements of the meaningful use program.

AHA President and CEO Rich Umbdenstock and AMA CEO James Madara called the meaningful use requirements “overly burdensome.” They added, “[W]e believe that the best way to move the program forward and ensure that no providers, particularly small and rural ones, are left behind is to realign the meaningful use program’s current requirements to ensure a safe, orderly transition to Stage 2.”

The groups offered four recommendations to improve the meaningful use program, including:

  • Allowing health care providers to meet Stage 1 meaningful use requirements using either a 2011-certified or 2014-certified EHR;
  • Establishing a 90-day reporting period for the first year of each new stage of the program for all providers;
  • Offering increased flexibility to providers in meeting Stage 2 requirements; and
  • Extending each stage of the meaningful use program to “no less than” three years for all providers.

Delay Stage 2 Meaningful Use For 12 Months

The American Academy of Family Physicians (AAFP) asked CMS to extend the timeframe for physician compliance with Stage 2 of the meaningful use program by 12 months.

Glen Stream, AAFP board chair, wrote, “We are increasingly concerned that the regulatory expectations of [meaningful use] Stage 2 and its current timeframe will outstrip the capacity of many certified electronic health record technology vendors and ambulatory family medicine practices.”

According to Stream, AAFP’s main concern is that members will not be able to manage key factors necessary for complying with Stage 2 of the program by the current deadline. Such factors include: Products; Implementations services; Training; and Support.

Stream outlined a plan that would change the compliance timeframe and create three distinct groups of physicians and other eligible professionals:

  • Group One would include providers who attest to meaningful use in 2014 as their first payment year and would follow a specific timeline for attestation to receive a 2014 bonus payment;
  • Group Two would include providers who attest to meaningful use in 2014 as their second payment year and would follow a separate set of specific EHR upgrade and reporting period guidelines to receive a 2015 bonus payment; and
  • Group Three would include providers who attest to meaningful use in 2014 as their third or fourth payment year and also would follow specific EHR upgrade and reporting period guidelines to receive both their 2014 and 2015 bonus payments.

The differing opinions among several prominent healthcare associations prove that there is no easy answer or simple solution. Each recommendation has its advantages and disadvantages. Yet, at the end of the day, the Office of the National Coordinator for Health IT (ONC) must make the final call in determining which course of action, if any, is to be taken.

In a recent interview, Dr. Farzad Mostashari, National Coordinator for Health IT,  addressed concerns about the timeline for launching Stage 2 of the meaningful use program. “If you’re in the more advanced half of hospitals or doctors and you were able to [meet Stage 1] earlier, you were able to get more of the money,” he said, adding, “That means that you also have to step up to Stage 2 in 2014 and Stage 3 in 2016.” Meanwhile, the “less ready half” would not need to “step up until 2015 for Stage 2 and 2017 for Stage 3,” Mostashari said. He also said that more products likely will be certified under the 2014 criteria for meaningful use but that more consumer protections also will be included.

Mostashari said that delaying the program “would stall the progress that’s been hard fought.”

Kentucky REC recommends that healthcare providers get ready to move forward with Meaningful Use Stage 2 as  planned.