We've had News Editor Joseph Goedert chained to his desk since late February, injecting coffee and carbohydrates into his tired body to keep him writing about the proposed Stage 2 meaningful use rules. His feature this month goes way deep into the rules and raises questions about a wide range of technological and reporting requirements. It's an exercise in analysis, not criticism, and his work-this story and prior reporting-provides I.T. leaders with an idea about what they're up against. (For his efforts, Joe got to walk around his backyard for 15 minutes, and change his socks.)

Something that really caught my attention in the feature is that some of the language in the proposed Stage 2 requirements seems to be setting the industry up for a Stage 4, an extra round that would stretch into the next decade. The passage, flagged by Debra White, a partner in the law firm Manatt, Phelps & Phillips, shows the progress through Stages 1 through 3 depending on when a provider starts, and then lists TBD "to be determined" from 2018 through 2021. Then this: "If there will be a Stage 4 of meaningful use, we expect to update this table in the rulemaking for Stage 3."

Well, that's interesting. According to U.S. Health and Human Services Secretary Kathleen Sebelius, the EHR incentive program as of February had sent more than $3 billion to some 2,000 hospitals and 41,000 physicians. She also lauded the fact that industry research estimates that the percentage of hospitals using EHRs doubled, from 16 percent to 35 percent, from 2009 to 2011.

That's a great stride, but this TBD makes me very nervous, because it seems to indicate the industry is looking at a perpetual motion regulatory machine, where EHR incentives and penalties just keep on coming, each more fiendishly clever than the next.

Many hospitals and eligible professionals are kicking EHR adoption into overdrive to avoid the Medicare reimbursement penalties, slated to start in 2015, for not being meaningful EHR users. But now here comes TBD ...

I.T. leaders are supposed to wrap this baby up in the next few years, and then get on with their lives.
But what if the program overstays its welcome? Incentives dwindle over time, penalties get more onerous, and all that incentive money starts flowing back to the source via penalties, investments in software to just keep up with meaningful use reporting requirements, precious brainpower diverted to coming up with ways to meet an ever-expanding list of core measures ... and ultimately the time not spent on out-of-the-box thinking on how to improve clinical care. That's a cost to be determined, but I think it would be astronomical.

Greg Gillespie, Editor-in-Chief, Health Data Management

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