When a Delay is Not a Delay – The Impact on Meaningful Use Stage 2

Much has been made about the Health Information Technology Policy Committee’s (HITPC) recent recommendation to the National Coordinator for Health Information Technology. Their recommendation, described in a presentation on June 8, 2011, was to delay the transition from stage 1 to stage 2 meaningful use requirements by one year. The problem with this recommendation, or more accurately with how it has been reported and interpreted by some, is that it’s only a delay for a relatively narrow group of hospitals, namely those who have or will attest to meaningful use in Federal FFY 2011. As of June 2011, this list included only about 40 hospitals out of 340 total eligible providers and eligible hospitals submitting for reimbursement.

The following table illustrates the impact of the recommended delays for hospitals attesting to meaningful use in FFY 2011:

 

In short, the timeline for Stage 2 for any hospital whose start year is after FFY 2011 has not changed. It’s only hospitals who decided (and were able) to demonstrate and attest to MU in the first program year that have been given an extra year between stages 1 and 2. The reason – if the Final Rule for Stage 2 isn’t released until Summer 2012 as expected, that would leave these early-adopters (and their vendors) approximately 3 months to plan for and implement the necessary infrastructure, software, training, etc. for Stage 2. That’s obviously an unreasonably short time frame that everyone, including ONC missed.

So what does this mean for hospitals and software vendors? At least three things:

  1. Although the timeline for Stage 2 has only changed for early-adopters, the broader market feels as if they have more time to make strategic and tactical plans for Stage 2, whether that includes purchase, upgrade or something else.
  2. This perceived extra time means they have an opportunity to make a more thoughtful/informed decision that will have a greater likelihood of success.
  3. Waiting on Stage 1 means hospitals actually have LESS not more time to decide on and implement a Stage 2 strategy (early-adopters get the extra year, later adopters will have the same short turnaround). A higher Stage 2 hurdle means it will be even more important that a hospital’s Stage 1 strategy and decisions will help them satisfy Stage 2 as well.
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About healthitjunkie

Over the past 18 years, I've had the pleasure of experiencing healthcare as a provider, administrator, technology vendor and enthusiast. Regardless of one's perspective or position, the challenge and promise of technology to impact healthcare has never been greater or more exciting. Although I'm passionate about healthcare technology, my "real" job is as a husband and father of two who also happens to enjoy cycling as much as possible.

Posted on July 21, 2011, in healthcare IT, meaningful use, ONC and tagged , , . Bookmark the permalink. 6 Comments.

  1. Keith W. Boone

    Not everyone missed this issue. Many of us commented on the time spans between stages, but were ignored until it became obvious to ONC and the HITPC.

  2. Keith, you are right in that some did not miss it. I originally wrote that “most” had missed it since that’s been my observation but then changed it to “some” before posting. Good on you for catching it as well. Would you agree the market (especially EPs and EHs) are interpreting it as a delay for all? Thanks.

  3. And congrats on the #HIT100!

  4. EPs and EHs who have already started on Stage 1 understand it I think. Those that have not don’t need to as it doesn’t affect them. If you start in this year, when you go for stage 2 standards, they will be in place.

  1. Pingback: The Meaningful User » Kudos to the Fog Cutter

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