Meaningful Use Deadlines Clash With Software Best Practices

When federal regulators announced plans to stretch the schedule for electronic health record (EHR) implementation under the Meaningful Use incentives program, they said one of the complaints they were responding to was a compressed timeline.

By the time requirements for software capabilities intended to enable Meaningful Use Stage 2 were finalized, vendors had too little time to translate them into working software, and healthcare enterprises had too little time to test, configure, and deploy the software. Those who managed to do so anyway -- or are well on their way to implementing software certified to the 2014 requirements -- may have felt a little foolish after learning of the proposed rule to allow users of software meeting the 2011 edition of the software to continue to qualify for the program.

Given more notice, most would have chosen to take the implementation a lot more slowly. One of the big reasons Meaningful Use is so challenging is the conflict between the program's ambitions for rapid change and the more cautious software implementation schedule favored by large enterprises, including hospital systems.

[Familiar pattern? Read ICD-10 Remains High Priority Despite Delay.]

In a joint announcement last week, the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health IT also said they would extend the Stage 2 phase of the program by a year, through the end of 2016, giving the healthcare industry more time to absorb and optimize the technology it has already implemented. Stage 3, which is expected to focus more on the outcomes that can be achieved with technology than on new IT requirements, would then begin in 2017.

It's more complicated than that, because the program really has two halves. One is the certification of software that meets the requirements of each Meaningful Use stage, known as certified electronic health records technology (CEHRT). The other is a set of quality metrics healthcare organizations are expected to meet to show they have used the technology in a meaningful way. Although this is the year of Meaningful Use Stage 2 for those organizations that started with Meaningful Use Stage 1 back in 2011 or 2012, organizations just now entering the program start at Stage 1. At the same time that they formulated their 2014 technology requirements, regulators adjusted the Stage 1 requirements to match what organizations ought to be able to accomplish with 2014 editions of the software.

To "clarify" the proposed rule, CMS had to publish a matrix of requirements that will now apply depending on whether an organization has implemented 2011 CEHRT, 2014 CEHRT, or a mix of the two -- and also depending on whether the organization plans to attest for Stage 1 or Stage 2 compliance this year. This is what that looks like:

Table 1: How Required Metrics Map To EHR Certification Year

Current Stage	2011 CEHRT	2011/2014 CEHRT	2014 CEHRT
Stage 1	2013 Stage 1 objectives and measures*	2013 Stage 1 objectives and measures* -OR- 2014 Stage 1 objectives and measures*	2014 Stage 1 objectives and measures
Stage 2	2013 Stage 1 objectives and measures*	2013 Stage 1 objectives and measures* -OR- 2014 Stage 1 objectives and measures* -OR- Stage 2 objectives and measures*	2014 Stage 1 objectives and measures* -OR- Stage 2 objectives and measures
*Only providers that could not fully implement 2014 Edition CEHRT for the reporting period in 2014 due to delays in 2014 Edition CEHRT availability.

Dr. Robert Wah, chief medical officer at consulting firm Computer Sciences Corp., welcomes the "encouraging signs of flexibility" demonstrated by the extension. He suggests every organization needs to study the proposed rule in detail to understand how it applies to them. Although the proposal still has to pass through a 60-day comment period, the proposal is a clear signal that the deadlines will be extended by at least this much.

True, the timing is such that organizations in the middle of the process of deploying technology or attesting for Stage 2 can't afford to slow down. However, the proposed rule suggests that the aim is to provide relief for organizations that were unable to obtain 2014 certified software in time to meet this year's Meaningful Use goals.

"The people who are on schedule will be fine," says Wah. "But there are a large number of people who will benefit from this flexibility."

Nevertheless, the ruling generated complaints from the American Medical Association, saying the requirements are still coming too fast, and the National Partnership for Women and Families, worrying that the promised benefits of health IT are being delayed. The College of Healthcare Information Management Executives (CHIME) welcomed the rule change but urged CMS to finalize it as quickly as possible.

As part of my research for our Healthcare IT Priorities Survey report, I recently spoke with CHIME board chair Randy McCleese, CIO of St. Claire Regional Medical Center, about the forced march that hospitals

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