I breathed a sigh of relief when CMS and ONC at last released the final rules on the second stage of the Meaningful Use EHR Incentive Program late last week. It had gotten to the point where people were asking me almost hourly if I had any idea when we’d have them. The rumor mill was in full swing … what was in and what was out?
And when we all finally got our hands on it, what was the first thing I looked for in the CMS rule?
You may recall that the program originally called for participants to report on 12 months of Meaningful Use activity to qualify for Stage 2 incentive payments. The problem, though, was that even with the proposed delay of the start of Stage 2 by one year, the length of time it was taking CMS and ONC to release the rules compressed the interval left for vendors and providers to execute. Requiring 12 months of reporting for 2014 was no longer plausible.
Why was this an issue? Most policy wonk-types don’t realize that it takes anywhere from six to 12 months for software vendors to develop, sufficiently test, and certify the software. And more importantly, it takes anywhere from three to 12 additional months for organizations to implement, test again and then train their providers to use it safely to a point where they can be successful “meaningful users.” Given all the time being eaten up by the regulatory development process over the last year, it was really a make-or-break issue, and we said so to anyone who’d listen.
Fortunately for providers, CMS took heed. We applaud CMS for reducing the reporting period for program participants in 2014 from 12 months to 90 days (the same reporting period required for Stage 1). The revised requirement gives providers flexibility when they implement their 2014 software edition, and in the meantime, they can focus on expanding their Stage 1 successes.
Hear, hear CMS!
One note of caution, though. Neither the quality measure specifications nor the test scripts that EHR providers need to move ahead with development are available, so the rules we have in hand aren’t exactly the “final package” needed for us to do the work to get our products ready. These detailed specifications are critical to our product development process, and while CMS halved the number of clinical quality measures for Stage 2 from what they’d proposed, we still estimate that complying with the rules will require thousands of hours of development work. And that doesn’t even address the certification test scripts…
Bottom line: Thank you to CMS and ONC for releasing the official rules, but please, keep it coming! None of us are done yet!
Do you think CMS did a fair job of handling the provider reporting period? Do you have other concerns about Stage 2? Register for our live webcast here, and leave a comment below.