Proposed Stage 2 Rules
OK, I’m finally ready to to start seriously thinking and talking about Stage 2. I keep remembering all the discussions that took place between the Stage 1 Proposed and Final Rules. Too much time was spent by too many people (I am guilty) trying to read the tea leaves and be prepared for every possible outcome. I don’t miss those days at all and have intentionally pulled back and allowed the Proposed Stage 2 Rules to wash over me. However, I now find myself thinking about a few of the “bridging issues” that lie ahead. I submit them for your consideration:
Sunset of “Complete EHR Technology” definition
The requirement for Eligible Providers (EPs) to have Complete EHR functionality was a headache for many specialists and technology vendors. Even if an EP was not required to meet some MU measures it was still required for Stage 1 that they possessed that functionality. This was true, even if the functionality would not, or could not (example: chiropractors cannot prescribe medications), be utilized. This “catch 22” has been elegantly addressed in the Proposed Rules by invoking the concept of a Base EHR. Here is the Proposed 2014 Edition Certification Criteria Required to Satisfy the Proposed Definition of a Base EHR and the Proposed 2014 Edition Certification Criteria Required to Satisfy the Proposed Definition of Complete EHR. This is a big deal for many EPs and vendors and it is a good thing. I’m sure we’ll see a little tweaking on this for the Final Rule but I expect it to emerge largely intact.
Stage 2 arrives in 2014 but some EPs will be at Stage 1
If an EP’s initial year in the EHR Incentive Program is 2014 they only have to meet Stage 1 MU objectives. Well, in 2014 when we have Stage 2 technology how can an EP use it to meet Stage 1 requirements with all the inherent modifications? Thank goodness someone has thought of this and generated a potential roadmap. Insight into these Stage 1 and 2 questions of transition can be found in the 2011 to 2014 Edition Certification Criteria Equivalency Table and 2011 and 2014 Edition Certification Criteria Crosswalk.
When the Rules are finally released we will have plenty of time to split hairs and hash the details but for now I hope you have a restful summer vacation. Remember to wear that sun block and if you that need a little more summer reading I direct you to the full ONC and CMS Rules.
Jim Tate is a nationally recognized expert on the CMS EHR Incentive Program, certified technology and meaningful use and author of The Incentive Roadmap® The Meaningful Use of Certified Technology: Stage 1