Hripcsak, a physician and the interim chairman of the biomedical informatics department at Columbia University, said that throughout the first and second quarters of 2011, his work group will monitor providers' progress in meeting Stage 1 criteria. But long before initial feedback comes in from subsidy program participants, Hripcsak said his as well as other work groups of the Health IT Policy Committee will have begun drafting more-stringent criteria for Stage 2.
The more-stringent Stage 2 criteria will cover fiscal 2013 and 2014. Work on developing them will begin Sept. 22 with a daylong work-group meeting, Hripcsak said.
By the next Health IT Policy Committee meeting Oct. 20, the meaningful-use work group will deliver its initial drafts of recommended Stage 2 criteria. Public input will be accepted once the initial drafts are released, and the work group plans to have a final draft ready for the full committee by the second quarter of 2011. Hripcsak said the hope is that the Health IT Policy Committee will make its final recommendations to the Office of the National Coordinator for Health Information Technology on Stage 2 criteria by late in that quarter.
Health IT Policy Committee member Richard Chapman said the policy advisers are faced with "a classic dilemma" of having a set schedule for producing Stage 2 criteria while the committee and its work groups are still receiving feedback from providers on how they're meeting Stage 1 criteria.
"We're going to have to ride our bike and fix it at that the same time here, which is, we're going to get feedback, but only so much of it we'll be able to be put into Phase 2," said Chapman, also executive vice president and chief administrative and information officer for Louisville, Ky.-based Kindred Healthcare. "Some will have to be staged later, even into (Stage) 3 or whenever we get there because I think we're going to find out there could be a showstopper along the way."
Under the stimulus law, to be eligible for federal IT subsidies, providers have to not only meet meaningful-use criteria but also do so using EHR systems that have been tested and independently certified as having the functionality to meet the new meaningful-use requirements.
Health IT entrepreneur Paul Egerman, a member of the Health IT Policy Committee and co-chairman of its adoption and certification work group, said he's concerned about the pace of new criteria development and whether EHR vendors, certification bodies and provider organizations will be able to keep up.
"The certification work group made a recommendation that this policy committee accepted that the certification criteria of Stage 2 had to be completed or well-known by April 1 of 2011," he said. And even if the criteria are complete by April 1, Egerman said, there's only an 18-month window until the Oct. 1, 2012, start of the Stage 2 eligibility period.
"What's really needed April 1 is pretty much like what you'd have in a first draft of an interim final rule," he said. The draft should provide, according to Egerman, specific details of the functionality required to meet Stage 2 criteria. "Then the vendors would have a chance to get it all done," he said.
Paul Tang, chairman of the meaningful-use work group, said the work group will have to dial up or dial down the difficulty and extent of changes for Stage 2 based on how well or poorly providers do with Stage 1 criteria.
"You'd calibrate the pace of the new functionality to the experience with Stage 1 and how aggressively you'll move in Stage 2," said Tang, a physician and the chief medical information officer of the Palo Alto (Calif.) Medical Foundation. Tang also serves as vice chairman of the Health IT Policy Committee.