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Thursday, June 16, 2011

What a delay would mean for MeaningfulUse Stage 2 Standards Regulation

Several people have been wondering publicly how the delay proposed by the HIT FACAs for phasing in Meaningful Use Stage 2 incentives would affect selection of standards.  Let me give you my viewpoint:

A delay in implementing incentives for stage 2 should have absolutely no impact on when the standards being used to meet the requirements for stage 2 will be chosen.  The whole point of the delay is to give the Healthcare industry enough time to respond to the new requirements.  If you delay the delivery of those requirements a year as well, then we still wouldn't have a clue as to what would need to be implemented, and delaying would have no gain.  So, expect an updated standards rule proposed by year-end that will tell us what new standards are being selected for stage 2.  My bet is that it will arrive the day before the Christmas holidays (it is the Office of No Christmas after all, and no summer vacations either).  We'll then get 60 days to comment (Jan-Feb), and then life will go dark again for 3 - 4 months while the final rule is developed and then published (July or thereabouts).

This is pretty much the same schedule for the standards regulation that was followed in 2010, and its been widely hinted that we can expect similar things for stage 2.

I'm not sure why the FACA chose a year long delay instead of the 90 day reporting option.  The latter seemed simpler and gains as much as 9 months (leaving it possible for organizations to move more quickly), while the former seems more complicated, gains 3 more months, but means that there's not much opportunity to move more quickly.  But then again, I've been down in the weeds of standards, rather than paying attention to what HITPC and HITSC are doing.

  - Keith


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