Murphy's work group generated 422 submissions to its request for public comments on its draft of proposed Stage 2 meaningful-use criteria it released in January. And in a meeting last week, the workgroup heard a preliminary report about the deluge of comments.
Almost immediately, the talk turned to the Oct. 1, 2012, effective date for Stage 2 compliance. It's a date that Congress, HHS, the Office of the National Coordinator for Health Information Technology, the CMS and, to be fair, the Health IT Policy Committee and its meaningful-use work group have had at least a hand in tentatively setting for Stage 2 meaningful use.
In reaction, legions of healthcare organizations have pleaded that they need more time.
I wrote about those pushback efforts in a story in this week's issue of Modern Healthcare.
Under the current timeline, a proposed rule on Stage 2 should be out by this December, but a final rule—one that EHR developers could write solid code against—probably won't be ready from the CMS until June or July of 2012, just a few months ahead of the Stage 2 effective date.
"There appears to be a groundswell movement," Miller said at the March 8 meeting. "And I’ve seen many different posts related to this, people sending it back and forth, especially the advisory board, recommending that people not look at doing qualification for Stage 1 meaningful use in 2011 because the timing for Stage 2 is going to be such that the vendors will not be able to have their code ready for Oct. 1, 2012."
As a result, Miller said, their contras' argument goes, "People will get locked out if they start their journey in 2011."
Several of the public comments I've read suggested moving back the start of Stage 2 for a year. Others have advocated using the same moving window of satisfying the meaningful-use criteria for the first year of Stage 2 that is currently in effect for the first year of Stage 1. That is, to qualify for a full year's federal incentive payment, providers would have to meet all the necessary meaningful-use criteria for 90 for consecutive days, but it could be the first 90 days of the one-year period, or the last 90 days or any 90-day period in between.