Delay in Meaningful Use Stage 2? Not really.

There has been confusion and questions circulating about the recent announcement regarding a new timeline for Meaningful Use Stage 2 and 3.   On December 6, 2013, CMS proposed a new timeline for Meaningful Use, extending Stage 2 for an additional year and delaying the start of Stage 3 to 2017.  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.

“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,” write Reider and Tagalicod.  “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 would allow certification data to be updated more frequently.  Read more.

What was less clear was the implication of this announcement regarding the START of Stage 2 in 2014. In a blog from John D Halamka, MD, MS, he states “This is NOT a delay of Meaningful Use in 2014 (Stage 1 or Stage 2).   All 2014 certification and attestation deadlines are still in force.”  Halamka is Chief Information Officer of the Beth Israel Deaconess Medical Center, Chief Information Officer and Dean for Technology at Harvard Medical School, Chairman of the New England Health Electronic Data Interchange Network (NEHEN), CEO of MA-SHARE (the Regional Health Information Organization), Chair of the US Healthcare Information Technology Standards Panel (HITSP), and a practicing Emergency Physician.

Here is what we know.  The proposal says the following:

  • The next set of required certification criteria will be the 2017 Edition which will support Stage 3 beginning in 2017.  This effectively extends the time of Stage 2 up to 3 years.
  • The CMS and ONC will be releasing their proposals in more official capacity via a Notice for Proposed Rule Making (NPRM) in Fall 2014 with the Final Rules expected to be released during “first half of 2015.”
  • This change in timeline was done primarily to collect more data to be better prepared for Stage 3.
  • ONC indicated it will be developing an optional 2015 Edition certification criteria set.

The proposal does not delay the start date for Stage 2 attestation.

In summary, the announcement is a first step in the fine-tuning of the national healthcare IT timeline.  Stage 2 is now a three-year cycle beginning in 2014, and Stage 3 begins in 2017.  There are no changes for the start of Stage 2 certification.  For Navigating Cancer, we are continuing to support your efforts for State 2 attestation.  We recommend that if you are planning to attest in 2014, that you continue on your path to making sure you are ready in 2014.

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