Meaningful Use Stage 2 Extension, MU Stage 3 Delay and New 2015 EHR Edition Certification Proposed

Posted on December 6, 2013 I Written By

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The big news of the week just came out of CMS at 4 PM EST on a Friday. Feels like they’re trying to bury the news story, but maybe it was just the way the timing worked out. Either way, there’s no way anyone who lives in the EHR and meaningful use would miss the announcement (not to mention I’ve already seen it posted on every major health IT news site). CMS is proposing an extension of meaningful use stage 2 another year through 2016 and so that means a delay in meaningful use stage 3 until 2017.

Here’s how Robert Tagalicod, Director, Office of E-Health Standards and Services, CMS and Jacob Reider, MD, Acting National Coordinator for Health Information Technology, ONC described the change in meaningful use timeline:

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 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.

Meaningful Use Stage 2 and 3
This shouldn’t come as a surprise to many. In fact, we’d been discussing the possible meaningful use stage 2 extension in the comments of my post: ICD-10 will be delayed. We thought meaningful use delay was possible, and now it’s happened.

I do like that this delay gives CMS and ONC more breathing room to know what to include in meaningful use stage 3. Plus, maybe they’ll get the MU Stage 3 certification requirements out in plenty of time for EHR vendors to be able to update their software.

One thing that is really interesting about this delay is that meaningful use stage 3 won’t go into effect until after the Medicare EHR incentive money is over. The Medicare EHR incentive money is only scheduled to be paid through 2016. Medicaid wasn’t implementing MU stage 3 until year 6, so I expect there’s no change there. While you won’t have to show MU stage 3 for Medicare EHR incentive money, you will have to attest to meaningful use stage 3 in 2017 if you want to avoid the EHR penalties (Payment Adjustments if you prefer CMS’ terminology). In 2017, those EHR penalties will be at 3%.

Many have called for a delay to meaningful use stage 2 as well, but that didn’t happen today.

2015 Edition EHR Certification
The other part of the CMS announcement is the 2015 Edition EHR certification. They propose having an additional 2015 EHR certification that sounds like it would amount to an update to the 2014 edition. The 2015 edition would fix any issues with the 2014 edition and update any changes to interoperability standards. Sounds like an EHR certification patch.

The catch is that EHR vendors that are 2014 Edition EHR certified wouldn’t have to do 2015 Edition. This is good since we don’t need software vendors having to certify again (as much as certifying bodies would love the new revenue). Although, I won’t be surprised if most EHR vendors take the new standards in the 2015 edition and update their software to those standards. Let’s just hope that if they choose to do so, it doesn’t kill their 2014 Edition EHR certification. We should all be using the latest and greatest standards. Even more important, we need to all be on the same standard.

What do you think of the announcement? I look forward to hearing your thoughts in the comments.

See Also:
HIMSS Response – HIMSS Supports Stage 2 Extension
CHIME Response – Meaningful Use Timeline Shift Does Not Afford Flexibility in 2014