The Centers for Medicare and Medicaid Services has added a third year to Stage 2 of the EHR meaningful use program and has delayed the start of Stage 3 until 2017. Providers with at least two years of participation in Stage 2 can start Stage 3--the criteria of which remains in development--in 2017.
However, the College of Healthcare Information Management Executives, after consulting with CMS, contends that extension of Stage 2 does not change current reporting timelines during 2014 and providers may or may not receive a third year of incentive payments under Stage 2 (see story).
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. Here is a statement from Robert Tagalicod, Director of the Office of E-Health Standards and Services in CMS, and Jacob Reider, M.D., Acting National Coordinator for Health Information Technology in ONC, released late in the day on Friday, Dec. 6:
Since the American Recovery and Reinvestment Act--which included the creation of the Medicare and Medicaid EHR Incentive Programs--was signed into law, the nation has seen unprecedented growth in the adoption and meaningful use of electronic health records. Between 2009 and 2012, EHR adoption nearly doubled among physicians and more than tripled among hospitals. Every month, thousands of providers join the ranks of hospitals and professionals that have adopted or are meaningfully using EHRs. As of October 2013, 85 percent of eligible hospitals and more than six in 10 eligible professionals had received a Medicare or Medicaid EHR incentive payment. Moreover, nine in 10 eligible hospitals and eight in 10 eligible professionals had taken the initial step of registering for the Medicare or Medicaid EHR Incentive Programs as of October 2013.
The Centers for Medicare & Medicaid Services today proposed a new timeline for the implementation of meaningful use for the Medicare and Medicaid EHR Incentive Programs and the Office of the National Coordinator for Health Information Technology proposed a more regular approach to update ONCs certification regulations.
Under the revised timeline, Stage 2 will be extended through 2016 and Stage 3 will begin in 2017 for those providers that have completed at least two years in Stage 2. The goal of this change is two-fold: first, to allow CMS and ONC to focus efforts on the successful implementation of the enhanced patient engagement, interoperability and health information exchange requirements in Stage 2; and second, to utilize data from Stage 2 participation to inform policy decisions for Stage 3.
The phased approach to program participation helps providers move from creating information in Stage 1, to exchanging health information in Stage 2, to focusing on improved outcomes in Stage 3. This approach has allowed us to support an aggressive yet smart transition for providers.
This new proposed timeline tracks ongoing conversations we at CMS and ONC have had with providers, consumers, health care associations, EHR developers, and other stakeholders in the health care industry. This timeline allows for enhanced program analysis of Stage 2 data to inform to the improvements in care delivery outcomes in Stage 3.
The proposed timeline for meaningful use would have a number of benefits, such as:
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;
More consideration of potential Stage 3 requirements;
Additional time for preparation for enhanced Stage 3 requirements;
Ample time for developers to create and distribute certified EHR technology before Stage 3 begins, and incorporate lessons learned about usability and customization.
Expected Timing for Rulemaking
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. All stakeholder comments will be reviewed and carefully considered before the release of the final rules.
What the New Timeline Would Mean for Providers
Eligible providers who have completed at least two years of Stage 2 would begin Stage 3 in 2017. We currently anticipate 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.
The new regulatory approach to certification that ONC is proposing would allow for certification criteria to be updated more frequently under the ONC HIT Certification Program. This approach is designed to provide public input on policy proposals, enable our certification processes to more quickly adapt to include newer industry standards that can lead to greater interoperability, and add more predictability for EHR technology developers. We also anticipate that this new approach would spread out over a longer time period than the certification requirements to which EHR technology developers have previously had to react.
Our first step under this new approach would be to publish a proposed rule for a 2015 Edition of certification criteria. We intend for the 2015 Edition certification criteria to improve on the 2014 Edition certification criteria in several ways. We expect the 2015 Edition would be responsive to stakeholder feedback; would address issues found in the 2014 Edition; and would reference updated standards and implementation guides that we expect would continue momentum toward greater interoperability. 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. Our intention would be for the 2014 Edition to remain the baseline certification criteria edition for meeting the Certified EHR Technology definition.
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