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:
- 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.
- This perceived extra time means they have an opportunity to make a more thoughtful/informed decision that will have a greater likelihood of success.
- 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.