In a recent paper, "Not so Fast—Why it Pays To Wait Until 2012 on Meaningful Use," published in February by the Advisory Board Company, Protima Advani argues that providers would benefit by waiting a year before applying for federal incentive funding.
She contends that total incentive dollars would be unchanged and that more time would be available to prepare for Stage Two. The hospital attesting to Stage One in late 2011 would have to be ready for Stage Two by October 2012, while waiting until early 2012 to attest would delay Stage Two requirements until October 2013. Stage Two requires compliance for the full year, unlike Stage One's 90-day reporting period.
In iHealthBeat Perspectives on March 31, Gerard Nussbaum suggests that waiting may not be the optimal approach—that providers with EHR adoption well under way should maintain the momentum. He suggests that only highly risk-averse organizations should consider delaying their applications.
I don't consider my organization to be strongly risk-averse, yet I have to take a realistic view of meaningful use and my readiness. We implemented the certified versions of both our hospital and our physician EHR systems, although this software wasn't ready at the beginning of Stage One because of the late finalization of the rules. We meet many of the compliance measures and are moving quickly on the remaining ones. Although we have to complete configuration and testing of the reporting software, we are confident that we can qualify and attest to meaningful use in 2011.
It is Stage Two that gives me pause. If we attest to Stage One meaningful use and receive payment in 2011, we will have just one year to prepare for Stage Two. Under the Medicare meaningful-use rules, a year missed following initial compliance is lost, not delayed. If we were not prepared for Stage Two by October 1, 2012, a payment approximately equal to 50% of the 2011 amount would be gone forever.
Stage Two requirements are only now being developed, with finalization expected in spring 2012, give or take a few months. The framework recommended by the Health IT Policy Committee's meaningful-use work group on December 13, 2010, is substantially more rigorous than Stage One, with higher compliance thresholds than Stage One and new requirements in areas like physician documentation and patient engagement. It will be further influenced by the recommendations of the President's Council of Advisors on Science and Technology, the Quality Measures Workgroup, and several other special-interest and working groups.
Waiting until early 2012 to apply for meaningful use does not reflect a loss of momentum. It does reflect a responsible consideration of the risks around HITECH readiness. After the Stage Two regulations are released, our EHR vendors will complete the required software changes and prepare to implement the upgrades for their entire customer communities in a compressed time frame. We providers will modify corresponding work flows and work with our clinicians to adopt the change necessary to meet the expanded requirements. It is highly unlikely that this can be accomplished in a few short months.
The decision to apply in 2011 or wait until 2012 is a matter of an organization's appetite for risk. Government regulatory processes, software development and deployment, and organizational change are traditionally areas of high risk for slippage. While Stage One in 2011 may be a "no-brainer," locking oneself into Stage Two in October 2012 may border on recklessness. Unless the Stage Two requirements are wrapped up soon and reflect reasonable progression from Stage One, providers will increasingly reach conclusions similar to mine.
Senior vice presidentChief information officerSharp HealthCareSan Diego