For the past several months rumors have been circulating that Meaningful Use Stage 2 (MU 2) will be delayed until 2014 – a one-year delay. This delay will impact 2011 adopters, since they will not be required to adopt the new MU criteria until 2014, instead of the current rule that requires 2011 attesters to adopt MU 2 in 2013. This delay will also impact all of the other healthcare constituents, including EHR vendors. EHR vendors will have an extra year to build any improvements into their software required by the new MU 2 rules.

In June, the Health IT Policy Committee, in a 12 to 5 vote, recommended delaying by one year (until 2014) Stage 2 of the Meaningful Use program for those providers complying with Stage 1 criteria in 2011. They were reacting to the many concerns from providers and electronic health record (EHR) vendors that 2013 was too aggressive a target for MU 2. The Health IT Policy Committee sent a letter to Farzad Mostashari, M.D. (he recently replaced Dr. David Blumenthal), the National Coordinator for Health IT, that the current schedule for compliance with Stage 2 objectives in 2013 posed, “a nearly insurmountable timing challenge,” for those who attested to Meaningful Use in 2011.

Farzad Mostashari, M.D.The delay to 2014 seems inevitable, since early this month Dr. Moshashari said that he approved of the recommendations by the Health IT Policy Committee for delaying MU2 until 2014. This was the confirmation that the healthcare industry was anticipating, regarding approval of the HIT advisory group’s recommendation by government policy makers.

Mostashari’s view is that providers who attest to meaningful use in 2011 should be rewarded, and by delaying the onset of stage 2 the government will be encouraging more providers to attest in 2011, since they no longer have to be early adopters of MU 2. He stated to the HIT committee, “The last thing we want to do is provide a disincentive towards attesting for meaningful use in 2011. We recognize that not accepting your recommendation to delay the start of stage 2 could negatively impact provider participation rates in the EHR incentive program in 2011.”

Does this sound like spin? It does to me, and it definitely demonstrates poor planning by the government. It is already July and to demonstrate MU for 2011 providers have just 3-4 months to get started for this year. Is this change in policy really going to change the course of MU adoption this year, probably not, the damage has already been done. The government spooked many providers by making MU 2 criteria vague and the adoption schedule for MU 2 too close to MU 1. They have already forced too many providers to the sidelines for this year because those providers did not trust that there would be ample time to prepare for MU 2. The truth is that the government is out of touch with the provider community. Their initial MU 2 recommendations do very little to simplify the practice of medicine for providers, and they are bumping up against a lot of resistance from providers and EHR vendors. They are buying some more time for everyone, including their own policy makers, to get MU 2 right.

Instead of recognizing that their MU 2 proposed guidelines (we will review in a future blog) need to be more provider-friendly, Mostashari recently remarked that, by giving providers and vendors additional time, requirements for stage 2 can be more rigorous. Is this any way to motivate the provider community?

He also remarked that, “… it makes sense to maintain the current expectations for those first attesting to meaningful use in 2012 so that all providers attesting to meaningful use in 2011 or 2012 would attest to stage 2 in 2014. Essentially, there is no “break” for 2012 first year adopters.

This delay was inevitable, because, at the onset of the MU program, the MU2 measures were never finalized. In fact, The Office of the National Coordinator for Health IT (ONC) and the Centers for Medicare and Medicaid Services (CMS) anticipate releasing their proposed rules on meaningful use of electronic health records (EHRs) and standards along with certification criteria by the end of 2011 or early 2012, accepting public comments about it, and finalizing it next summer. Based on that schedule it would have been impossible for providers and vendors to “gear up” in just six months for a 2013 MU 2 start date.

Recap

  • Meaningful Use Phase 2 was originally slated to start in 2013.
  • Previously only providers that were recognized MU users in 2011 had to start MU 2 in 2013.
  • Previously providers that started 2012 had until 2014 to start MU 2.
  • The government has not finalized the requirements for MU 2 yet.
  • The government may not finalize MU 2 requirements until the summer of 2012.
  • It appears that because of these delays that MU 2 will be delayed until 2014.
  • Whether a provider starts MU 1 in 2011 or 2012, they will both start MU 2 in 2014.
  • Some providers delayed starting MU 1 in 2011 because they feared a hurried start of MU 2.
  • Now providers that are ready to start MU 1 in 2011 will have the time they deserve to prepare for MU 2.

Timeline View of Recent Meaningful Use Events

Meaningful Use Timeline Meaningful Use 2 Start Date

It appears everyone can now take a deep breath and not feel hurried regarding Meaningful Use Stage 2. But there are still many questions that must be answered about MU 2. In a future blog we will discuss the preliminary recommendations regarding MU 2, and how they will impact the provider community. This delay gives the provider community the opportunity to push for EHR standards that help to simplify the practice of medicine, and I hope we take advantage of it. In the meantime, the best news is that being an early adopter of MediTouch® technology means that you will have extra time to prepare for MU 2 – great news for our providers that are cashing their checks this year!