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Carol Kulczyk, PMPVITL Director of Program Implementation

Meaningful Use –2012 and Beyond

MU Stage 2 Delay

• Initial proposal– Presented Summer of 2011– Delay Stage 2  for providers who attested to Stage

1 in 2011

Rationale?

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From HHS Statement• "Input from the vendor and the provider communities

makes clear that the current schedule for compliance with stage 2 meaningful use objectives in 2013 poses a nearly insurmountable timing challenge for those who attest to meaningful use in 2011. …..the current timetable would require EHR vendors to design, develop, and release new functionality, and for eligible hospitals to upgrade, implement and begin using the new functionality by the beginning of the reporting year in October of 2012.”

MU Stage 2 Delay• On 11/30/11, HHS announced a Stage 2 delay

to 2014– “Pioneer” providers attesting in 2011 can now

wait until 2014 to fulfill Stage 2 requirements– Providers who begin Stage 1 attestation in 2012

could already wait until 2014 to fulfill Stage 2– So now everyone will start Stage 2 in 2014

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More from HHS Statement

• "Not only do we believe that this will give vendors added time to develop certified EHR technologies for Stage 2, we also believe this delay will give providers additional time to implement new software and meet the new challenges of Stage 2.”

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Other 2012 Activity• HITECH MU Incentive Audit Strategy

– Proposal is in progress– Guiding principles

• Imperative that an audit process is established to ensure that proper payments are made to eligible providers and hospitals.

• Also important that providers and hospitals do not perceive the process of applying for incentive payments to be burdensome and thus affect their willingness to adopt EHR systems and participate in the program.

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Other 2012 Activity• HITECH Audit Strategy (continued)

– Any provider attesting to receive an EHR incentive payment for either the Medicare EHR Incentive Program or the Medicaid EHR Incentive Program may be subject to an Audit.

– The Audit Strategy should be flexible enough to accommodate the Stage 1 attestation process and evolve to incorporate Stages 2 & 3 criteria and their collection methods.

– Stay tuned for more info.

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Other 2012 Considerations

• Potential Challenges with EHR Vendors – Some vendors have acknowledged software “bugs”– Some service and support deficiencies reported– Let VITL know!

Questions?