8 Notes About Changes to EHR Stage 2/Stage 3

CMS and ONC recently extended Stage 2 of the EHR meaningful use program, delayed the start of Stage 3 by a year until 2017, and tweaked the EHR certification program. But the actions aren’t as much of a reprieve to providers as they might appear; there are tradeoffs. Here’s a look at the changes.

Calendar Change Calendar Change

Stakeholders have argued the industry is not ready for Stage 2 and asked for a delay. Instead, they got an extension--Stage 2, originally scheduled for 2014 and 2015, now also will continue in 2016.

The extension of Stage 2 was made to give policymakers and the industry more time to get ready for a "robust" set of criteria in Stage 3 focused on improving outcomes.

Readying Stage 3 Readying Stage 3

Stage 3, with development of criteria still in the early stages, now begins in 2017 when providers with at least two years of participation in Stage 2 can begin. CMS anticipates that eligible professionals would begin in January 2017, at the start of the calendar year, and eligible hospitals and critical access hospitals would begin in October 2016, at the start of the federal fiscal year, which continues present timelines.

Touted Benefits Touted Benefits

The government says the changes will bring multiple benefits: More analysis of feedback from stakeholders on Stage 2 progress and outcomes; More available data on Stage 2 adoption and measure calculations--especially on new patient engagement measures and health information exchange objectives.

Disagreements Disagreements

Benefits aside, the College of Healthcare Information Management Executives, after consulting with CMS, contends that extension of Stage 2 does not change current reporting and attestation timelines and providers may or may not receive a third year of incentive payments under Stage 2. Hospitals still need to start collecting data by July 2014 for their first reporting period in October, and eligible professionals have to start collecting data by October 2014 for the January 2015 reporting period, CHIME CEO Russ Branzell says. Not only are reporting periods unchanged for providers starting Stage 2 in 2014, but also for providers starting Stage 1 in 2014 to avoid reduced Medicare payments in 2015.

What About Payments? What About Payments?

Stage 2 extended by a year means that providers will report on Stage 2 for up to three years, but not necessarily get incentive payments for three years. There are scenarios depending on when a provider began meaningful use that the provider could receive three payments in Stage 2, but the present number of possible payments throughout the program has not changed, CHIME’s Branzell says. So, if a provider takes off 2014 and doesn’t start meaningful use until 2015, they will lose a year of incentive payments. CMS confirmed Branzell’s explanations to Health Data Management.

ICD-10 or MU? ICD-10 or MU?

CHIME will continue to communicate with CMS and members of Congress on the need to shift reporting periods so providers aren’t starting Stage 2 at the same time they are trying to finish ICD-10 work. Branzell believes CMS does not want to delay Stage 2 reporting periods because that would delay seeing benefits from the program. But if providers have to choose between being ready for ICD-10 or meaningful use, they will pick ICD-10 because its impact on revenue is so much greater.

EHR Certification Changes EHR Certification Changes

CMS also has proposed a voluntary “2015 Edition” EHR certification program with upgraded standards and implementation guides to continue momentum toward enhanced interoperability, but providers and vendors are not required to upgrade EHR systems. “We expect to propose that the 2015 Edition would be voluntary in the sense that providers participating in the EHR Incentive Programs would NOT have to upgrade to 2015 Edition EHR technology and NO EHR technology developer who has certified its EHR technology to the 2014 Edition would need to recertify its products."

Timing for Stage 3 Rules Timing for Stage 3 Rules

CMS and ONC said in a statement that, "We expect that in the fall of 2014 CMS will release a notice of proposed rulemaking (NPRM) for Stage 3 and a corresponding ONC NPRM for the 2017 Edition of the ONC Standards and Certification Criteria will be released in the fall of 2014, which will outline further details for this proposed new timeline."

"The final rule with all requirements for Stage 3 would follow in the first half of 2015."

CMS and ONC recently extended Stage 2 of the EHR meaningful use program, delayed the start of Stage 3 by a year until 2017, and tweaked the EHR certification program.


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