The government's decision to postpone Stage 3 meaningful use by extending Stage 2
for a year is not the good news it appears to be, TMA says in a letter to
Centers for Medicare & Medicaid Services (CMS) officials.
is deeply disappointed that CMS has not recognized the importance of extending
the 2014 meaningful use requirements and the start of the penalty period,"
wrote Joseph Schneider, MD, chair of the TMA Ad Hoc Committee on Health
Information Technology. "Many of our members have not yet received their 2014
certified software from their ambulatory EHR vendors. Once they finally receive
the upgraded software, it can take many months to test and install, including fixing
the bugs that will surely exist as many EHR vendors have rushed this into production.
For some, that will leave only the July-September 2014 attestation period for physicians
to meet meaningful use and avoid the 2015 penalties."
Schneider added that TMA "considers this deadline to be dangerous to patient
safety and physician practice viability, as Stage 2 requires an enormous change in the management process. Penalizing physicians who take the time to carefully test their
software and manage their practices does not indicate an appreciation of
patient safety on the part of CMS."
he said, TMA "recommends that physicians be required to meet only a subset
of meaningful use measures to avoid the penalty rather than the full set required
to receive the incentive. CMS set the precedent of lesser requirements for penalty
prevention with the e-prescribing program, which required physicians to e-prescribe
10 times to prevent the penalty and 25 times to receive the incentive. Organized
medicine is happy to work with CMS to identify the subset of measures that could
be met for penalty prevention."
CMS said it will extend Stage 2 through 2016, and Stage 3
will begin in 2017 "for those providers that have completed at least two
years in Stage 2. The goal of this change is two-fold: first, to allow CMS and
ONC [Office of the National Coordinator for Health Information Technology] to focus efforts on the successful implementation of the enhanced patient
engagement, interoperability and health information exchange requirements in
Stage 2; and second, to utilize data from Stage 2 participation to inform
policy decisions for Stage 3."
Schneider also told CMS that evidence is increasingly clear "that an abrupt
switch to ICD-10 on Oct. 1, 2014, will bring massive disruptions to health care.
The public and our members are not willing to tolerate these disruptions. We strongly
recommend that the period during which either ICD-9 or ICD-10 claims can be filed
be extended to Oct. 1, 2016, to give the industry sufficient time to adjust. Failure
to address this issue indicates a failure of leadership in Washington."
For more information about
the meaningful use program, EHRs, or other health information technology
issues, contact TMA's HIT Department by phone at (800) 880-5720 or by email.
Action, Dec. 16, 2013