The registration process and reporting period for the meaningful use incentive program officially commenced on Jan. 3. More than 21,000 health care providers have registered to date and many more are ramping up efforts to meet meaningful use criteria and collect federal incentives in fiscal year 2011. However, rushing out the gates in FY 2011 is extremely risky and not advisable. In fact, the Advisory Board Company strongly recommends waiting until FY 2012 to first demonstrate meaningful use.
Three key reasons hospitals should wait until FY 2012 are outlined below.
Compressed, unreasonable timeline for achieving Stage 2: The final rule states hospitals that first demonstrate meaningful use in FY 2011 will need to achieve Stage 2 by FY 2013 (i.e. Oct. 1, 2012). Furthermore, hospitals must demonstrate meaningful use requirements for the entire year in Stage 2 as opposed to the 90-day reporting period for the first year that a hospital is a meaningful user. Unfortunately, the final rule defining Stage 2 requirements will not be finalized until mid-2012, leaving hospitals that first demonstrate meaningful use in 2011 with less than six months to meet Stage 2 by Oct. 1, 2012. This will be an unattainable leap for health care providers, especially because Stage 2 is being positioned as a step down from Stage 3, not a step up from Stage 1. Stage 2 comprises enhancements to Stage 1 requirements in addition to a host of new, more complex criteria and clinical quality measures. Furthermore, hospitals will be dependent on their vendors’ ability to rapidly develop, test and seek certification for the Stage 2 EHR capabilities, adding another barrier to provider Stage 2 meaningful use achievement in the short time frame available. In contrast, waiting until FY 2012 to first demonstrate meaningful use will afford hospitals nearly 18 months to migrate from Stage 1 to Stage 2 — a more adequate time frame to acquire, implement and adopt the required capabilities for Stage 2.Continue reading…