Much of the debate over stage 2 has centered on concerns that the
industry will not be ready to progress from stage 1 in 2013.
quality measures in 2013, then adding new EHR functionality
Not all providers would benefit from a delay. Those who were
capable of meeting the stage 2 requirements in 2013 would lose
incentive payments if the stage were pushed back a year.
An Early Look at the Requirements
The Health IT Policy Committee released a preliminary draft of
stage 2 meaningful use criteria for public comment in January.
The draft, created by the committee’s meaningful use workgroup, was intended to alert the industry to potential new EHR
functionalities, start the public comment process, and gather
responses to 10 specific questions.
The recommendations came in the form of a matrix that plot-ted stage 1 criteria, proposed stage 2 criteria, and in many cases,
proposed stage 3 criteria. The committee included the stage 3
criteria for context, because it conceives of stage 2 as a stepping
stone to stage 3. However, it was interested primarily in comments on stage 2 at the time.
The objectives addressed four of the five health outcome priorities established in stage 1. The draft did not cover the privacy
and security domain, which the committee’s privacy and security subgroup is addressing in recommendations to be released
separately. In addition, the draft did not address quality measures, which are moving forward in a different workgroup.
For the most part, the recommended stage 2 objectives heightened the measures of stage 1, although some objectives and
their measures were unchanged. Objectives from the menu set
in stage 1 were upgraded to requirements in stage 2. The draft
included eight new objectives in the four domains that have no
precedent in stage 1.
No PCAST in the Forecast
Whatever the final stage 2 requirements will be, they are unlikely to incorporate recommendations made by the President’s
Council of Advisors on Science and Technology in its December
The council’s recommendations to create a “universal exchange language” are not feasible by 2013, according to a joint
workgroup of the policy and standards committees that studied
the report. The workgroup found that there is not enough time
to write and test the criteria. It also noted that the council’s recommendations lacked real-world examples that would speed
their incorporation into the meaningful use program.
Next Up: Waiting
The full Health IT Policy Committee is expected to review the
workgroup’s formal recommendations at its June 8 meeting.
From there the committee expected to forward its final recommendations to ONC for consideration in the forthcoming proposed regulation on stage 2.
At that point the ball is in ONC’s court. Much of the talking
will be done, and the waiting will begin. ONC, working with the
Centers for Medicare and Medicaid Services, will draft a proposed regulation establishing the stage 2 criteria, which it expects to publish at the end of this year. A final rule is expected
by the middle of 2012. Unless the timeline is changed, stage 2
would begin in 2013.
Over the summer and fall ONC will also be at work updating
the IT certification and standards requirements related to the
stage 2 criteria. Those guidelines direct vendors in preparing
their systems to qualify for use in stage 2 of the program. ¢
Kevin Heubusch ( firstname.lastname@example.org) is editor-in-chief of the
Journal of AHIMA.