December 10, 2013
CMS and the Office of the National Coordinator for Health Information Technology (ONC) have just proposed significant changes to the timeline for Meaningful Use / MIPS Stage 2 and Stage 3. But, what must be made immediately clear, is that no changes are being made in the Meaningful Use / MIPS certification and attestation deadlines for 2014. The announced changes do result in all providers receiving an extra year in Stage 2 before progressing to Stage 3. According to ONC’s posting on their blog:
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. 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 announced delay is an extension to the end of Stage 2, and not a delay of Meaningful Use / MIPS in 2014. Those struggling to meet Stage 1 Meaningful Use / MIPS by the October 14, 2014 deadline and participate in the incentive program, still face the same struggles. Those providers who first attested in 2013 still have another year in Stage 1, and those who first attested in 2011 or 2012 still have to attest to Stage 2 for the first time in 2014.
For many in the industry, the new shift in the Meaningful Use / MIPS timeline is a positive, but doesn’t go far enough. HIMSS responded with disappointment, noting that CMS has not addressed its recommendation to CMS that an additional six months be given to providers to certify their compliance with Stage 2. Similarly, officials at the College of Healthcare Information Management Executives (CHIME) expressed their dismay that the extension “does not afford much needed flexibility to providers working to install and upgrade new technology.”
Why their frustration? Of all the challenges providers are facing in their immediate Meaningful Use / MIPS projects, lack of vendor readiness is one of the most significant. Many EMRs are still not certified to meet Stage 2. This places hospitals behind the curve to begin their implementation projects for this complex upgrade.
Another key challenge hospitals face is provider adoption of the Meaningful Use / MIPS standards. Providers who have been unable to deploy their MU2 compliant EMRs face a very short implementation cycle to make the significant changes in workflow and documentation standards required for MU2 compliance, prior to beginning their 90 day measuring period for 2014.
This is not to say that the additional year at the end of Stage 2 isn’t of value. CMS will have the opportunity to gather additional data and feedback from facilities that have implemented Stage 2, prior to promulgating rules for Stage 3. The improvements in the rulemaking process and the time in Stage 2 will be of great benefit to vendors in preparing their packages for Stage 3, and should allow providers a more relaxed pace for meeting the Stage 3 deadlines beginning in 2017.
But, the bottom line for providers in the trenches today is the same as it was before the CMS announcement. There’s a lot of work to do, and the time and resources to do it are limited.
What are your opinions about CMS’ announcement? Will the extra year in Stage 2 make a difference for your organization?