The American Academy of Family Physicians is asking the federal government to start Stage 2 of the electronic health records program on time, but to extend the compliance timeframe by a year.

The association, in a letter to CMS Administrator Marilyn Tavenner and ONC leader Farzad Mostashari, M.D., is concerned that regulatory expectations of Stage 2 and its existing timeframe will outstrip the capacity of many EHR vendors and ambulatory family practices to comply. “Though we do not wish to impede the progress of early adopter physicians poised for MU Stage 2 on January 1, 2014, we do not wish to see other family physicians who have committed to health care transformation through the thoughtful application of health I.T. to abandon the MU journey due to factors beyond their control.”

AAFP’s letter explains how extending Stage 2 compliance by a year would set up three distinct cohorts of physicians complying with meaningful use in different ways:

“Cohort 1 would include those eligible professionals attesting to MU in 2014 as their first payment year. They would be expected to implement 2014 CEHRT (certified electronic health record technology) and complete a reporting period of one quarter under MU Stage 1 prior to January 1, 2015, to receive their 2014 payment. In 2015, these EPs would be expected to complete an additional two quarters of MU Stage 1 prior to January 1, 2016 to receive their 2015 payment.”

“Cohort 2 would include those EPs attesting to MU in 2014 as their second payment year. They would be expected to upgrade from 2011 CEHRT to 2014 CEHRT and complete a reporting period of one quarter under MU Stage 1 criteria prior to January 1, 2015, to receive their 2014 payment. In 2015, these EPs would be expected to advance to compliance with MU Stage 2 criteria and complete a one-quarter reporting period prior to January 1, 2016, to receive their 2015 payment.”

“Cohort 3 would include those eligible professionals attesting to MU in 2014 as their third or fourth payment year. They would be expected to upgrade from 2011 CEHRT to 2014 CEHRT, advance to compliance with MU Stage 2 criteria, and complete a reporting period of one quarter prior to January 1, 2016, to receive their 2014 payment. By completing any two quarters under MU Stage 2 criteria prior to January 1, 2016, they would receive both their 2014 and 2015 payments.”

The complete AAFP letter, including a graph visually demonstrating the three-prong proposal, is available here.

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