Stage 2 and 3 Proposals

[Thomas, Cheyenne A.--IRM (Silva)]

Good Morning Everyone,

Attached please find a document that I created this morning based on the ONC Policy Committee discussion and documents relating to their initial stage 2 and 3 recommendations.  A couple of items to keep in mind as you review this document include:

• This is only the initial recommendations and will go through several iterations
• I copied proposed stage 2, proposed stage 3 and comments directly from their document but the bold, italics items in the comments column are my additions based on the discussion surrounding each item
• Dr. Blumenthal came in late and made a comment regarding the report that I sent out earlier that may change this list to be more aggressive anywhere that exchange is referenced
• A number of workgroup members stressed that they have learned that the completeness of front-end demographics and their accuracy are the key to the rest of the information (of course we already knew this) so expect demographics to be perhaps enhanced and get more attention - One proposal is that all demographic data be "normalized" and standards applied that are identical for all EHRs and all output
• There are a number of infrastructure initiatives (NHIN Direct, Entity-Level Provider Directories, etc…) that are being moved along to be available for stage 2 and will have an impact on how these objectives are implemented
• They stated that they have not addressed the administrative objectives here but expect CMS to include (claims, eligibility, etc..)
• There is still some discussion around changing the timeline (specifically mentioned was could there be a possibility of moving stage 2 to 2014)  My opinion is this will be decided at least in part on how quickly confirmed stage 2 proposals are put out (i.e. will there be enough time for vendors to create new programs and then will there be enough time for providers to implement them and change their process accordingly)
• I have listed the timeline they are looking at below although they are not very optimistic that this will materialize
• They have discussed the fact that they expect to require a certified PHR to be part of the complete EHR for stage 2


• Dec, 2010: refine draft MU criteria, prepare for RFC
• Jan, 2011: release draft MU criteria RFC
• Feb, 2011: collect RFC submissions
• Mar, 2011: analyze RFC submissions and revise MU draft criteria
• April, 2011: present revised draft MU criteria to HITPC
• 2Q11: CMS report on initial MU submissions
• 3Q11: Final HITPC recommendations on stage 2 MU
• ~4Q11: CMS MU NPRM

The meeting is still ongoing (it started at 6 AM this morning) but I wanted to get this info out to everyone.  If there is more to report, I will send it out later.

<<potential_stage 2_3_onc.docx>>

Thanks,
Cheyenne Thomas
INHS/IRM
Manager, Regional Accounts
509-232-8180
thom...@inhs.org

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