With Stage 2 of CMS's Meaningful Use EHR incentive program set to roll out at the start of 2014, there has been some speculation that the program might be delayed in order to give physicians more time to prepare. At this article's time of printing, no official word has been given as to when Stage 2 will begin. One thing is certain, however: Physicians can likely expect several changes, no matter when the transition occurs.
The Year Ahead: What's In Store
Perhaps the most important consideration for physicians is that if CMS declines to extend the deadline for the start of Stage 2, beginning next year anyone who has satisfied Meaningful Use requirements—for two years—must switch to Stage 2. Thus, anyone who started receiving incentive dollars in 2011 or 2012 will be required to meet the minimum criteria for Stage 2.
Among the significant changes in Stage 2 as compared to Stage 1 of the incentive program is that Stage 2 requires virtual patient portals. Specifically, HHS will require five percent of your total patients seen to request clinical information online. Importantly, such contact must be a clinical information exchange. The clinician may also initiate contact, which may encompass how a patient is responding to a treatment or whether they need a refill.
The other major difference is that physicians only need to comply with the rule for 90 days to qualify. However, the qualification period for clinical quality measure is only available on a quarterly basis. This may be a difficult adjustment for some physicians. Vendors, too, may find it more of a challenge to update their software to ensure Meaningful Use-readiness for specific periods of 90 days.
Regarding the “calendar quarter” requirement for qualification for Stage 2 benefits, it would be natural for physicians to wait until the final quarter of 2014 to qualify. While this might appear to be the most attractive option for physicians who want more time before qualifying for Stage 2, it is also worth considering that the new ICD diagnostic codes go into effect on October 1, 2014. Thus, if you are hoping for a smooth transition from ICD 9 to ICD 10, it might not be wise to also attempt to qualify for Stage 2 incentive dollars at the same time, as you would essentially be undergoing two significant transitions at the same time. Therefore, it makes the most sense to begin qualifying for Stage 2 of Meaningful Use in one of the first three quarters of 2014.
Delay or No Delay
Whether or not Stage 2 is delayed, EHR users still face much uncertainty going forward. While a delay would certainly allow users and vendors to prepare for the patient portal and other less significant changes, it would not likely have a impact on current forecasts for EHR adoption rates. By contrast, for those who have been qualifying for Stage 1 since 2011, it would mean that they have collected the maximum amount of incentive dollars for Stage 1.
Mark Kaufmann, MD is co-chair of the Dermatology workgroup for CCHIT. He is on the Medical Advisory Board of Modernizing Medicine.