Meaningful Use change is afoot in the world of EHR software. Many doctors, hospitals and EHR vendors were set up to step away from meaningful use stage 2. Many would have filed for an exception, others would have opted out of Medicare, and others would have just taken the penalties on the chin. It wouldn’t have been pretty and the people at CMS/ONC/HHS realized this was happening and had to do something to avoid the meaningful use stage 2 fall out. It wouldn’t have looked good to have billions of dollars of EHR incentive money sitting on the table with no one wanting it.
CMS decided to cover this wound with a bandaid fix that essentially delays meaningful use stage 2. There are still a lot of details of the proposed rule that are unclear. For example, can anyone attest to meaningful use stage 1 or is that option only available to those EHR vendors who aren’t ready for meaningful use stage 2? I’ve sent that question to CMS, but still haven’t gotten an answer.
Can you imagine the fallout if this is indeed the case? Basically they’d be saying, “All of you EHR vendors and organizations that were good and stayed up with the latest regulations are going to have to do more work and attest to the stricter MU2 criteria while we reward those EHR vendors and organizations that weren’t ready for MU2 with a simpler option.” Can you imagine the backlash that would occur if this is indeed what they decide to do? For that reason alone, I can’t imagine them keeping it that way. I think they have to just open up all the stages/certifications to anyone and everyone regardless of your EHR vendor’s readiness for MU2. (
Note: I haven’t dug in to see if this is really a viable option or if a 2014 Certified EHR required changes to the software which make it so it can’t do both MU2 and MU1, but I think it should work out fine. For example, CQMs are tied to certification year and not MU stage. Update: Lynn Scheps from SRSSoft sent me the following update “Prior to the publication of the proposed rule, 2014 CEHRT was required for everyone who wanted to earn an incentive in 2014, so part of the certification requirements was that the EHR could be used for stage 1 or stage 2.”)
What’s even more important is that this is really just the start of the meaningful use revolution. I’ve pointed out my article to “blow up meaningful use” a few times before and that message is starting to be shared by other healthcare IT influencers. For example, the title of this post came from a post by EHR certification and Meaningful Use expert, Jim Tate’s post “You Say You Want a Meaningful Use Revolution” which was a great follow up to his “Meaningful Use Zombie Land” post.
It has become really clear that there’s a lot of confusion afoot. The thing people want most from government regulation is clarity and ICD-10 and now meaningful use are suffering from a lack of clarity. John Halamka summarizes this issue really well:
at some point we need to recognize that layering fixes on top of existing Meaningful Use regulation, some of which was written by CMS and some of which was written by ONC creates too much complexity. I have direct access to the authors of the regulations and email them on a daily basis. It’s getting to the point that even the authors cannot answer questions about the regulations because there are too many layers. I realize that we are reaching the end of the stimulus dollars, but as we head into Stage 3, I wonder if we can radically simplify the program, focusing on a few key policy goals such as interoperability, eliminating most of the existing certification requirements, and giving very clear direction to hospitals and professionals as to what must be done when.
I’m glad to see that John Halamka and myself are on the same page. We need to simplify meaningful use and focus on interoperability. That’s a simple and clear message that providers will understand. I was excited that EHR vendor athenahealth offered a similar view in their post “We Should Be Pushing Interoperability Boundaries, Not EHR Certification Timelines.”
Jim Tate has a good call to action to those who care about what’s happening with meaningful use. As of last night, only 8 comments had been made during the public comment period for the meaningful use stage 2 delay NPRM. You can submit your comments on the rule incredibly easy at the following link: http://www.regulations.gov/#!documentDetail;D=CMS-2014-0064-0002 I’ll be taking this post and my “blowing up meaningful use” and modifying them as my comments. I hope you’ll take the time and share your thoughts on the delay and the future of meaningful use.