Timeline Changes for Meaningful Use

There seems to be still some confusion around what exactly the announcement on Friday December 6, 2013 by the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) means. First is a new timeline for the implementation of meaningful use for the Medicare and Medicaid EHR Incentive Programs. This change has simply added a third year to Stage 2 of the EHR meaningful use program and has delayed the start of Stage 3 until 2017. Providers with at least two years of participation in Stage 2 would be able to start Stage 3 in 2017, while providers who have started in either 2011 or 2012 will have an additional year of Stage 2.

The second change is the new regulatory approach to certification that ONC is proposing. First, it seems they are going to be soliciting even more stakeholder feedback in the process and giving clearer signals to developers on what will be expected. They intend to publish a proposed rule for a 2015 Edition of certification criteria which will improve on the 2014 Edition certification criteria. However, this new certification will be completely voluntary (and therefore likely to not be part of most organizations upgrade path). As the ONC explained:

"We expect to propose that the 2015 Edition would be voluntary in the sense that providers participating in the EHR Incentive Programs would NOT have to upgrade to 2015 Edition EHR technology and NO EHR technology developer who has certified its EHR technology to the 2014 Edition would need to recertify its products. Our intention would be for the 2014 Edition to remain the baseline certification criteria edition for meeting the Certified EHR Technology definition."

So while CMS and ONC are beginning to make some small changes to timelines and certification processes, this seems to be a small step in the right direction. As John Halamka pointed out, "This is NOT a delay of Meaningful Use in 2014 (Stage 1 or Stage 2). All 2014 certification and attestation deadlines are still in force." While I have written in the past about the need for greater flexibility in meeting Stage 2 requirements, this change does not address those concerns. Although I believe there are very likely more changes to come, it is very important that healthcare organizations and providers do not count on any delay or changes, but prepare for plans to proceed under this current current regulatory framework.