Ask Adele: December questions answered by Adele Allison
Friday, December 13, 2013
Posted by: Joy Ingram
Adele Allison is the National Director of Government Affairs, SuccessEHS. SuccessEHS is a non-voting member of NWRPCA
What's all the Buzz About the Meaningful Use Extension?
Question: I have heard that CMS is delaying Meaningful Use. Can you set me straight on just what has happened and how this might play into my 2014 plans to participate in Meaningful Use?
Indeed there is movement afoot related to Stages 2 and 3 Meaningful Use timeline.
In a blog post on Dec. 6, 2013, sister agencies under the U.S. Department of Health and Human Services (HHS) – Centers for Medicare and Medicaid Services (CMS) and the Office of National Coordinator (ONC) – revealed their plans to extend the original timeline for adoption and use of certified electronic health record technology (CEHRT) under the federal entitlement program known as "Meaningful Use." Launched in 2011 and requiring hospitals and clinicians to move from paper to electronic patient records, the CMS Medicare and Medicaid EHR Incentive Programs were scheduled to be rolled out in 3 stages through 2015. The new timeline would extend the roll out through 2017.
The announcement by Robert Tagalicod, director of the CMS Office of E-Health Standards and Services, and Jacob Reider, M.D., acting head of the office of national coordinator for health information technology (ONC), sets forth their intent to lengthen the period for Stage 2 through 2016 thus delaying stage 3 until 2017. In so doing, these agencies will gain expanded opportunity for Stage 2 program analysis creating a springboard for policymaking that would use health IT and data to increase quality and improve performance in Stage 3. The specific benefits cited by Tagalicod and Reider include:
- Greater analysis of Stage 2 stakeholder feedback and outcomes;
- More data on Stage 2 CEHRT workflow adoption, including the use of health IT for patient engagement and health information exchange;
- Ability to leverage Stage 2 information for informed and responsive Stage 3 policy-making;
- An 18-month lifecycle for industry design, development and distribution of technology meeting Stage 3 requirements;
- Incorporation of lessons learned.
Transition through Meaningful Use and other health IT programs such as the patient-centered medical home (PCMH), the physician quality reporting system (PQRS), and the ICD-10 changeover plays a critical role in health care reform. Data captured under these many programs will become measured, reported and publicly published to support patient engagement, public transparency of provider performance and reimbursement reform under the Affordable Care Act (ACA). Specifically, the software industry's ability to deliver usable, strong products to their customers will determine the winners and losers as data is used to purchase value over volume through programs like the CMS value-based purchasing modifier (VBPM) and performance models such as Accountable Care Organizations (ACOs).
Why the shift in policy timelines? Amplifying the voice of multiple stakeholders that HHS was moving too quickly with its Meaningful Use requirements and roll-out, 17 Senators sent a letter to Secretary Kathleen Sebelius on September 24, 2014, asking for an extension of Stage 2 so that providers who needed additional time would have it. One week later the federal health insurance Marketplace opened, having anything but an optimal go-live with much being chalked up to aggressive development and implementation timelines. The Senators called for a response by Oct. 8th – amidst a 16-day federal shutdown that began on Oct. 1st, as well. This recently revealed plan by HHS is both timely and responsive.
Does this change the launch date of Stage 2?
No. Stage 2 will commence on Jan. 1, 2014 for eligible professionals (EPs) as planned.
However, under the Meaningful Use programs, all providers must use technology that meets the latest ONC testing and certification standards regardless of the meaningful use stage for which they are striving. Today that standard is the 2014 Edition. Formal testing and certification allows regulators to ensure the roll-out of standards-based health IT that is consistent, safe and secure for patients. Therefore, starting Jan. 1, 2014, both Stage 1 and Stage 2 EPs must use 2014 Edition CEHRT.
The ONC has also indicated that it will propose a voluntary 2015 Edition criteria that seeks to improve upon the 2014 Edition by incorporating industry comments and correcting any issues found with a keener eye towards greater interoperability. In the scheme of U.S. policy-making, the Meaningful Use programs and certification are young. Much has been learned since the launch in 2011, and much remains to be discovered as the programs advance. For this reason, neither EPs nor vendors would be required to upgrade or recertify to the higher 2015 Edition standard. The 2014 Edition will be considered baseline.
What does this mean for my practice?
The growing intricacies associated with such requirements as interoperability has resulted in a long-predicted narrowing of players in the marketplace. Make sure you have the right technology partner on a going forward basis. As providers mature in adoption of EHR, so too do the development complexities. Software companies that can adopt, adapt and guide will make for enduring success. The 2014 Edition requirements have resulted in an 87.5 percent decrease in the number of companies and organizations that measure up to the challenge. This shake up has created a rapidly growing replacement market estimated at 17 percent in a July, 2013 Black Brook Rankings report.
The extension is a positive step for providers and industry stakeholders with the right partner – one that has been 2014 Edition certified for months. If your vendor falls in this category, this frees you to use the time expansion for controlled and responsible growth and achievement. If your vendor is not yet 2014 Edition certified, now may be the right time – while ample bandwidth exists – to find the right technology partner who can carry you into the future.
What are the next steps?
1. Remember that this was a blog post only. Formal rulemaking will flesh out the details. Stage 2 Meaningful Use has not been delayed, but extended allowing for a delay in the launch of Stage 3. Expect proposed rules to be published in the fall of 2014, with the Stage 3 final rules to be released during the first two quarters of 2015.
2. Follow the intended path for transition, which supports and positions you for health care reform, namely: Stage 1 → Consistent Data Capture; Stage 2 → Data Interoperability; and, Stage 3 → Using your data to improve care quality and outcomes.
3. Evaluate your current technology solution to ensure you have the right partner. If you are on a system that is not 2014 Edition certified today, your vendor is behind. As complexities grow, it will become increasingly difficult to stay current. Replacing software today will be easier than replacing software tomorrow.
4. Keep your eyes and ears open for additional details to come.
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