Stick with the current plan: Stage 2 would take effect in 2013, and providers would have to meet Stage 2 requirements for a full year to be eligible for incentive payments. (For the first year of the program, providers seeking Stage 1 incentive payments have to demonstrate that they've met Stage 1 requirements for only 90 days.)Dr. Paul Tang, a physician with the Palo Alto (Calif.) Medical Foundation who serves as both vice chairman of the Health IT Policy Committee and chairman of the work group, explained that the change of timing in the third option would apply only to those hospitals and eligible professionals seeking federal EHR incentives in the first payment year of the Medicare portion of the program.
"It creates the time for the vendors and the providers to create a new program," Tang said. "Option 3 gives us that breathing room."
The work group is scheduled to present a final draft of its Stage 2 recommendations at the full committee's June 8 meeting for final approval. If approved, the recommendations will be forwarded to the Office of the National Coordinator for Health Information Technology at HHS and to the CMS for further deliberation and for formal rulemaking. A proposed set of Stage 2 rules could be issued by the end of 2011, with a final rule due by mid-2012.
