This appears to be our summer of discontent when it comes to Stage 2 of the Meaningful Use program, as the Jan. 1, 2014, start date looms ever closer. A number of stakeholders decided it was time to weigh in and suggest that Stage 2 be somehow delayed, modified, or both. Here's a sampling:
- The Medical Group Management Association (MGMA) has asked the U.S. Department of Health & Human Services to extend reporting for Stage 2 by at least one year and delay the penalties to be imposed on providers who are not meeting the Meaningful Use requirements.
- The American Academy of Family Physicians (AAFP) requested an extension and a softer, tiered implementation structure.
- The American Medical Association (AMA) and American Hospital Association (AHA) asked for an extension of each stage, a softening of the requirements and greater flexibility in meeting those requirements.
- The College of Healthcare Information Management Executives (CHIME) and its members would like an extension.
- The Health Information and Management Systems Society (HIMSS) doesn't want a delay but would like the attestation requirements to be extended.
- And Sen. Orrin Hatch (R-Utah), who arguably can be called a stakeholder, in July called for a "pause" and reassessment of the program, a request that Republicans in Congress have made in the past.
I'm not sure whether HHS should delay implementation of Stage 2 in whole or in part, or whether it should soften the requirements. Arguments surely can be made on both sides.
But it does appear that the real issue isn't the concept of advancing to Stage 2. It's whether the providers and the vendors have the capability to meet the requirements. Word is out that vendors are still scrambling to meet 2014 certification requirements, and that providers--many of whom haven't even attested to Stage 1--are unprepared for the next stage.
HHS is pretty savvy. It will backtrack, delay and soften requirements when it appears that its original design was just too ambitious.
And it's done this before. Just look at the Affordable Care Act. HHS recently delayed the employer mandate by a year. And in July, it softened its requirement that consumers verify their income and health insurance status before allowing them to participate in the exchanges. Now people only have to attest that they qualify. It is my understanding is that the technology to perform this verification electronically is simply not in place yet; just last week, HHS delayed signing contracts with insurance companies for the new insurance exchanges.
HHS has already delayed Stage 2 once--in November 2011--ostensibly to encourage faster EHR adoption. I hypothesized then that the decision may also have been to enable more providers to meet the requirements, and to give HHS itself some breathing room.
We might see this very same scenario again. It's better to take a step back and make sure that the program, and its participants, are given every chance to succeed. Otherwise, it will simply fall flat.
And, to borrow a phrase, it's really just too big to fail. - Marla (@MarlaHirsch)