Members of the HIMSS Electronic Health Record Association, in a comment letter on initial draft Stage 2 meaningful use criteria, call for a period of at least 18 months between a final rule on the criteria and the beginning of Stage 2.

The association also asks for consideration of delays in starting Stage 2, or shifting from three two-year stages for the program to two three-year stages.

"With the time required to develop software, perform adequate quality assurance, obtain ONC-ACB certification, and deploy the software in provider organizations (including internal testing, implementation of new features and end-user training), currently proposed timelines are simply not sufficient--particularly as regulatory pressures on providers are exacerbated by 5010, ICD-10 and other regulations that will go into effect in the next 24 months," according to the vendors.

The organizations offer a half-dozen options that could mitigate concerns about short timeframes:

* Define Stage 2 criteria sooner than currently anticipated, with detailed requirements and technical specifications 18 months before the beginning of Stage 2.

* Limit Stage 2 to increased adoption of Stage 1 measures, by increasing performance thresholds but using Stage 1 software functionality and reporting capabilities.

* If specifications for new features are not made available with a lead-time of 18 months, a "feasibility panel" of vendors and providers could determine whether responsible and safe deployment is possible in the prescribed timeframes. If the panel deems the timeline unsafe, the new features would be postponed until Stage 3 "or later."

* Delay the start of Stage 2 and the expiration of the 2011-2012 EHR certifications. "Begin Stage 2 in 2014 for the earliest group of adopters while maintaining the current schedule of publishing specifications to allow for safe development and implementation. Extend '2011-2012' certification for a year to be '2011-2013' certification. This could include collapsing the three two-year stages into two three-year stages."

* Introduce a 90-day reporting period for the first year of each phase and a corresponding timeline for use of software certified to the new specifications.

* Allow providers earning Medicare incentives to be able to "skip a year," similar to the Medicaid incentive program.

The association's complete comment letter is available at himssehra.org.

--Joseph Goedert

 

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