The Medical Group Management Association is calling for physicians successfully completing Stage 1 of the electronic health records meaningful use program to not face financial penalties for failure to meet the requirements of Stage 2.
In a letter to Health and Human Services Secretary Kathleen Sebelius, MGMA expresses concerns about the current meaningful use environment and the “diminished opportunity” for physicians to meet Stage 2 criteria. There are only 75 software products and 21 Complete EHRs certified for Stage 2 as August 21, the association notes. “This lack of vendor readiness has significant implications for eligible professionals. Without the appropriate software upgrades and timely vendor support, EPs will be unable to meet the Stage 2 requirements and thus will be unfairly penalized starting in 2015.”
Absent appropriate steps being taken, “we believe physicians that have made significant investments in EHR technology and successfully completed Stage 1 requirements will be unfairly subject to negative Medicare payment adjustments. Accordingly, HHS should immediately institute an indefinite moratorium on penalties for physicians that successfully completed Stage 1 meaningful use requirements.”
In addition to vendors not being ready for Stage 2, eligible professionals who invested considerable resources in their Stage 1 certified EHR are being forced to “rip and replace” it with a certified Stage 2 product, which MGMA calls “an unrealistic and unreasonable demand as the cost to the practice would be prohibitive and the disruption to organizational workflow and patient care would be significant.”
Market forces also are making Stage 2 compliance difficult, the association asserts. Some vendors have postponed software upgrades, while others are focusing on ICD-10 compliance. “Even if a vendor does upgrade their product to meet the Stage 2 criteria and successfully certifies this product late in 2013 or sometime in 2014, these products must still be deployed to the client practices and staff trained on the new software and new Stage 2 reporting requirements. This deployment and training process itself can take a year or more, depending on the vendor.”
To further aid physicians in becoming and remaining meaningful users, MGMA asks HHS to extend the reporting periods for Stages 1 and 2, build additional flexibility into Stage 2 reporting requirements (particularly view/download/transmit), and conduct a comprehensive vendor survey to understand which Stage 2 requirements vendors are unable to meet and which vendors will be recertifying products for Stage 2.
Text of MGMA’s letter to Secretary Sebelius is available here.
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