The Association of Medical Directors of Information Systems would like to know just how much flexibility is in the extra room that federal officials offered last month to participants in the electronic health-record
incentive payment program who are unable to meet its Stage 2 requirements.A proposed rule
would allow certain physicians and hospitals preparing to move to the more stringent Stage 2 requirements to receive waivers if they attest that their efforts were thwarted by circumstances beyond their control. AMDIS board member Dr. Michael Zaroukian has been authorized by the association to draft a formal response to that proposal.
One of the conditions in the proposed rule that providers could cite in requesting a waiver is if they are unable to fully implement an EHR in time because of delays caused by systems developers, Zaroukian noted.
“Many of us wonder what do we need to do to demonstrate we were unable to fully implement” a system that needed to be tested and certified to the 2014 Edition criteria, he said.
“There is one thing to say they didn't have it (tested and certified) in time,” he said, but does that include those providers whose vendor had a system tested and certified, but “we couldn't implement it because we were on a waiting list, or we couldn't implement it and get the interfaces installed, or even if we could get it implemented, we couldn't do the workflow (changes)?”
Under the proposed rule, those who started in the EHR incentive payment program at Stage 1 in 2012 will still need to advance to Stage 2 in 2015 as previously scheduled. “It will be interesting to see how many people can do that in two years,” he said.
AMDIS' comments also expect to address broader issues than the current EHR implementation troubles, Zaroukian said. For both Stage 1 and Stage 2, the government originally planned that each stage last only two years, only to be forced by the inability of providers and developers to meet those timelines to push them back.”
Going forward, Zaroukian said, “Is two years in any one stage enough? We actually haven't proven that.”
AMDIS is hosting its annual Physician-Computer Connection Symposium this week in Ojai, Calif.Follow Joseph Conn on Twitter: @MHJConn