Couple of weeks back the HIT Policy Committee began to seriously consider what a delay of Stage Two meaningful use (MU) might look like. This push for a delay is being driven in large part by EHR vendors. The problem is one of timing. While Stage Two rules are to be released on June 8, 2011, there is growing concern among these software companies that they simply will not have enough time to build, test and deploy the required functionality in time for their customers to demonstrate meaningful use and pick-up their incentive check at the Medicare window.
This does not come as a surprise. When the HITECH Act was first passed as part of the broader Stimulus Bill (ARRA), the primary objective, at least for ARRA and subsequently HITECH, was getting people back to work. The HITECH legislative language was purposely vague highlighting such key objectives as getting physicians to “meaningfully use” a “certified EHR” to promote “care coordination.” Since this was a jobs’ bill, the legislative language also pushed for the billions of dollars in HITECH funding to be doled out expeditiously.
Problem is, installing software into an existing operation is just a tad more difficult than say resurfacing a roadway. When you layer into that software installation issues such as changes in workflow, training clinicians, insuring patient safety is maintained (and ideally improved) you end up with a very challenging situation. In the case of HITECH, this challenge is further compounded by the desire to continuously improve, via the proposed three stages of MU requirements, the quality of care delivered. These are the challenges providers and hospitals are facing but as mentioned previously, the EHR vendors are struggling as well to deliver the functionality required to meet future meaningful use requirements.
Last week at the Massachusetts Governor’s Healthcare IT Conference both Dr. Blumenthal and Dr. Halamka gave their perspectives on this conundrum of whether or not to delay Stage Two MU. Blumenthal was quite cautious in his statements that basically inferred that such a delay could have some repercussions on the entire HITECH Act wherein some of the funding may be retracted if it was not spent in the timeframe allotted to it under this legislative act. In today’s acrimonious federal budget wrangling on the Hill this is a very real possibility.
Halamka proposed another scenario wherein Stage Two would be split into a Stage 2A and 2B. Meeting Stage 2A would not entail new software functionality, but simply attestation that the provider/hospital was meeting the stepped up implementation of their EHR. For example, in Stage One, the CPOE requirement is for 30% of patients to have at least one order via CPOE. In proposed Stage 2, the requirement is 60% of patients. No new software functionality is required, just more physicians trained on how to use CPOE. Stage 2B would address those MU requirements that are new and requiring additional EHR functionality (e.g., record a longitudinal care plan for 20% of all patients).
What is likely to happen?
Looking into its analyst’s crystal ball, Chilmark foresees the following:
- Stage Two will be delayed in some form or fashion as there has been a lot of grumbling by healthcare providers who have struggled to meet Stage One (and even Stage One was significantly water-downed from what was first proposed).
- Halamka’s scenario of Stage Two being broken up into two makes sense as it addresses both legislative issues (keeps ball rolling) but also allows the industry time to add new functionality and subsequent training to ensure safety.
- The delay in full Stage Two MU requirements will put significant pressure on Stage Three with Stage Three subsequently pulled. Those requirements outlined in Stage Three will be achieved through other approaches that HHS has at its disposal, e.g., payment reform.
Good post John. Very helpfull!
Thanks for bringing this issue to the front burner. This is big. Not quite as big as the earth’s poles shifting, but still pretty big.
Agreed Jim, this is a pretty big deal and will impact the plans/strategies of both healthcare organizations and the EHR vendors that serve them.
Thanks yet again for a clear, sane and appreciated explanation.
Do you think this will affect (good or bad) the ACO formations and their incentives?
Hard to say Adam as to what effect the release of Stage Two will have on the formation of ACOs. For those ACOs that are being formed outside of CMS proposed rules, impact is likely to be minimal. For ACOs that are formed under CMS proposed rules (NPRM) (these rules are only proposed and there has been significant push-back already) there could be an issue as the NPRM does require that 50% of physicians in the ACO be meaningful users of an EHR. So, does that mean meaningful in the sense of Stage One? What about subsequent Stages, must they demonstrate MU for these as well? Still very unclear.
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