Dear CMS/ONC: For Meaningful Use, give providers some breathing room, too

Pardon my cynicism, but I'm not overly impressed with the proposal to extend the timeline for Stage 2 of the Meaningful Use program and delay implementation of Stage 3 by the Centers for Medicare & Medicaid Services and the Office of the National Coordinator for Health IT.

Let's look at the agencies' stated two-fold goal for extending the timeframe: "to allow CMS and ONC to focus efforts on the successful implementation of the enhanced patient engagement, interoperability and health information exchange requirements in Stage 2; and second, to utilize data from Stage 2 participation to inform policy decisions for Stage 3."

And let's take a look at the benefits of the proposed timeline, as outlined by the agencies:

  • More analysis of feedback from stakeholders on Stage 2 progress and outcomes;
  • More available data on Stage 2 adoption and measure calculations--especially on new patient engagement measures and health information exchange objectives;
  • More consideration of potential Stage 3 requirements;
  • Additional time for preparation for enhanced Stage 3 requirements;
  • Ample time for developers to create and distribute certified EHR technology before Stage 3 begins, and incorporate lessons learned about usability and customization.

These are laudable goals that I applaud. Of course it's great that the government will more thoroughly assess the successes and deficiencies of Stage 2 so as to better mold Stage 3. This will make Stage 3--and future stages--more practical and sustainable.

But it begs the question: weren't CMS and ONC supposed to do this to begin with? Did they just realize that they need more time?

Now certainly there's nothing wrong with a reassessment. I presume that CMS and ONC don't want a repeat of the HealthCare.gov roll out debacle, which has, in large part, been blamed on insufficient planning and rushed, sloppy implementation.

But what about the providers who have been burdened with trying to gear up for Stage 2 and have been begging for months for some reprieve, including delay of the penalties and tiered implementation? As Robert Tennant, senior policy advisor for the Medical Group Practice Association stated at Dec. 6 CMS' eHealth Summit just hours before CMS and ONC's announcement, the move to Stage 2's certification requirements are a "huge heavy lift for the industry."

And what about some of the other unsolved problems with the program, also addressed at the summit, such as  the "all-or-nothing" pass/fail approach to attestation, forced reliance on patients to meet attestation and lack of reimbursement for electronic communication? 

I know that CMS and ONC have a lot on their plates, and that at the same time, their budgets have been slashed. I understand their desire for more time on the clock.

Funny, though, that's the same boat that providers are in. Let's not set them up to fail. If CMS and ONC get some breathing room, perhaps the providers should, too. - Marla (@MarlaHirsch @FierceHealthIT)

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