All Three Stages of Meaningful Use in Play

“All the world’s a stage, and all the men and women merely players.” So goes the opening of one of Shakespeare’s most famous monologues. As we anticipate the release of the final rule for Stage 2 all three stages are being played out.

Stage 1 Meaningful Use:

October 3rd Last Day for EPs to Begin Reporting – In an email from CMS last Monday, the agency reminded us of the EHR Incentive deadline of October 3rd. This will be the last day for eligible professionals to begin their 90-day reporting period for calendar year (CY) 2012 in the Medicare EHR Incentive Program. For EPs, this means that they must begin their consecutive 90-day reporting period by October 3rd in order to attest to meeting meaningful use and be eligible to receive an incentive payment for CY 2012.

Meaningful Use Attestation Audits Begin – Some healthcare providers that have attested to Stage 1 Meaningful Use received audit letters late last month. Though not officially announced, HHS has designated the accounting firm of Figloiozzi and Company to begin auditing. On the CMS.gov attestation page CMS makes it clear any provider attesting to receive EHR incentive payments for either the Medicare or Medicaid program may be subject to audits and lists what providers need to know to be prepared.

Stage 2 Meaningful Use:

Stage 2 Final Step – In July the CMS NPRM on Stage 2 Meaningful Use was sent to the Office of Management and Budget (OMB). This is the final step before it makes its grand entrance and is published in the Federal Register. In concert with MU, the ONC EHR Certification and Standards Final Rule was also sent to the OMB for review. There is still much speculation on when the final rulings will be released once the review process is complete. We think they’ll make their appearence sometime in September.

How a Stage 2 Delay Affects Stage 1 – Upon the release of the NPRM for Stage 2 MU Jim Tate offered his thoughts on how Stage 1 and Stage 2 will be bridged. Read his Stage 2 Bridging Issues post from June.

Stage 3 Meaningful Use:

Recommendations for Stage 3 – The HIT Policy Committee Meaningful Use Work Group has begun making recommendations for stage 3. On the table and of keen interest to all is Patient Engagement which will take on a bigger role. The Federal Advisory Committee workgroups hosted a hearing to explore how patient-generated health data (PGHD) could fit into meaningful use of EHRs in Stage 3. Mary Mosquera offers more insights into Stage 3 draft recommendations currently in play.

And will Stage 3 be the finale –  Not so says Standard Geek Keith Boone.  He speculated we’ll see a Stage 4 and perhaps more on his MU Live! guest appearance in June.