The change only affects providers whose first incentive payment year is 2011, since they are the only providers who would be subject to Stage 2 regulations in 2013 had the delay not been implemented, everyone was already entitled to 2 years of meaningful use at Stage 1.
Those provider’s who have attested to Stage 1 in 2011, now can earn 3 years of incentives under the less stringent requirements of Stage 1 (only if they are willing to forego their Medicare ePrescribing bonuses). Foregoing ePrescribing bonuses can be very costly for high-revenue, high-volume Medicare providers – be very careful here!
This announcement has no impact on eligible hospitals that had not already attested in 2011, only eligible providers who have not yet attested.
It seems counterintuitive that a delay in a deadline would encourage faster adoption rates by providers. Here is how the incentive is intended to work:
Prior to the Delay
- If a provider completed Stage 1 Meaningful Use in 2011, they would have to complete Stage 2 Meaningful Use by 2013.
- If a provider completed Stage 1 Meaningful Use in 2012, they would have to complete Stage 2 Meaningful Use by 2014.
After the Delay
- Stage 1 demonstration and attestation would continue through 2013.
- Stage 2 would start in 2014.
- Stage 3 would start in 2015.
With the revised timing, providers will still receive the same payments as originally planned. Instead of 2013, however, early entrants will have to wait to attest and receive payments for Stage 2 in 2014.
HHS claims to be working towards a realistic balance between achieving desired results of EHR implementation with the practical realities that providers are facing in implementing EHR systems. Only time will tell.
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