Jim Tate, Meaningful Use Expert

Stage 2 Meaningful Use Requirements Expected Soon

So the holidays have past and we can all ease back into the well-known and comfortable understanding of Stage 1 Meaningful Use and incentives. Correct? Well don’t get too deep in that couch. Sure the incentives are flying into inboxes at a record pace. In November 2011 alone over $585,000,000 was paid out to Eligible Professionals and Eligible Hospitals as incentives. I hope Santa brought you your share. For you Medicare EP folks 2012 is the last year to enter the program in order to get maximum incentives. For those that qualify in the Medicaid program no such sword hangs over your head. As long as you acquire, upgrade, or implement certified EHR technology no later than 2016 you will leave no incentives on the table. But let’s not get to relaxed. The focus now shifts to Stage 2 meaningful use and the milestones are coming up fast.

I expect proposed Stage 2 requirement either this month or next. This will be followed by a public comment period and then a rigorous review of all comments and subsequent modification of the requirements. Sometime in the summer of 2012 we will have the final definitions of Stage 2 certification criteria and meaningful use objectives. Right now is a quiet period for EHR vendors. They will have to probably put off next summer’s vacation as they scramble to implement the  new required functionality and go through Stage 2 certification. Those ONC-ATCBs will have backlogs as the vendors rush to certify so maybe they should take a long Spring Break. Maybe a week or two in Cancun.

I expect Stage 2 to be a major step forward in terms of required EHR functionality and use. There were lots of smoke and mirrors in Stage 1. Very few in Stage 2. Get ready for the gnashing of teeth by those who will say that Stage 2 is just too hard. We know that Stage 3 is the endpoint so Stage 2 cannot be incremental, it must be monumental.

Jim Tate is a nationally recognized expert on the CMS EHR Incentive Program, certified technology and meaningful use and author of The Incentive Roadmap® The Meaningful Use of Certified Technology: Stage 1.