Everyone is talking about how Stage 2 of meaningful use has been postponed to 2014 (Yes, HHS has made it official), but what exactly are its implications? First off, providers whose first incentive payment year is 2011 are going to be affected since they are the ones who would be subject to Stage 2 regulations in 2013 if it weren’t for the delay. However, as for the rest of the providers, the delay doesn’t mean much since they are already entitled to 2 years of meaningful use at Stage 1.

The press release from HHS says, ““To encourage faster adoption, the Secretary announced that HHS intends to allow doctors and hospitals to adopt health IT this year, without meeting the new standards until 2014. Doctors who act quickly can also qualify for incentive payments in 2011 as well as 2012.”  We have one bone of contention here. Don’t you think it’s a bit too late for providers to decide to adopt health IT this year (let alone change any adoption-related behavior or to accelerate EHR adoption!)?

But wait! The announcement has more to it, “Perhaps most importantly, we want to provide an added incentive for providers attesting to meaningful use in 2011.” Looks like it’s more about accelerating attestation rather than it is about increasing adoption? Apparently, the goal is to encourage physicians who were already using certified EHR technology in a “meaningful way” to attest and to collect an incentive payment this year (instead of holding off attesting until 2012), which in turn would create a potential PR benefit for the incentive program. Thought the incentive program currently boasts nearly 115,000 registered providers, only 9% of the registered providers have successfully attested.

Talking about the benefit of the schedule delay, early adopters are the luckiest since they can now earn 3 years of incentives under the less stringent requirements of Stage 1 (They will have to say goodbye to their 2011 Medicare ePrescribing bonuses, though and we must say it isn’t such a good deal).

Plus, the HHS statement has also acknowledged the pushback from providers regarding how challenging even the Stage 1 requirements are. So, to truly spur program participation and EHR adoption, we think all providers, and not just the early adopters, should be entitled to 3 years of meaningful use under Stage 1 rules. And if CMS is so doubtful about physicians succeeding at Stage 2, don’t you think it should reconsider how stringent it plans to make the requirements?

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