Amid the abundant (and yet unanswered) pleas from all quarters to extend or delay Stage 2 comes some potential good news about the scheduling of Stage 3: It’s becoming clearer and clearer that Stage 3 won’t start for anyone before 2017—at the earliest.
Although I have not seen any formal announcements by CMS or ONC confirming this, a recent legislative update from the EHRA (the HIMSS EHR vendor association) reported that the proposed rule on Stage 3 is not expected until late 2014. There are many steps and a defined timeline that transpire between the release of a proposed rule and implementation of the final regulations in the field. First, there is a 90-day comment period, during which all stakeholders have the opportunity to express their support and/or concerns about every aspect of the proposed rule. Then, the government needs another 90 days or so to consider each comment and create the final rule, in which it responds to these comments. That takes us to mid-2015. To give the EHR vendors anything short of 18 months to complete product development, test usability, deploy their upgraded software, and train their clients would meet with overwhelming resistance. Implementation of Stage 3 before 2017 would be highly unlikely.
This breathing room is a good thing for physicians. As I have discussed in prior EMR Straight Talk blogs, meaningful use has essentially stifled innovation by driving EHR vendors to focus the lion’s share of their development efforts on government requirements. Now physicians will benefit from the vendors’ ability to deliver the innovative workflow enhancements that providers need, and they will have time to hone their workflows to more efficiently meet the government’s requirements.