Late Friday afternoon, the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health IT (ONC) jointly announced some timeline changes for stages 2 and 3 of meaningful use. Stage 2 will be extended one year, pushing the start date for stage 3 back to 2017. Providers will have an extra year to meet stage 2 requirements, just like they did with stage 1.

According to the press release, “The goal of this change is two-fold: first, to allow CMS and ONC to focus efforts on the successful implementation of the enhanced patient engagement, interoperability and health information exchange requirements for Stage 2; and second, to utilize data from Stage 2 participation to inform policy decisions for Stage 3.”

There is still some confusion regarding how the timeline changes will affect providers, though.


At first glance, it may seem like CMS has given providers an extra year to prepare for stage 2, but that is not the case. Providers have an extra year to meet stage 2 requirements, yes, but it still begins in 2014 for those who have demonstrated meaningful use of stage 1 for two years.

Since providers are only required to attest to stage 2 for two years before moving on to stage 3, and now that stage 2 encompasses three years instead of two, does that mean providers will need to shoot for “best two out of three” attestation during that time period? That is unclear at the moment, but most likely providers will have to meet stage 2 until stage 3 starts, even if it means they attest to stage 2 for three years.

The same thing happened with stage 1 of meaningful use. Originally, it was supposed to last two years, but CMS added another year to allow more providers to participate and qualify for incentives. Early meaningful users still had to attest for three years.

Even though the timeline changes won’t affect the providers’ preparations for 2014, most are grateful for the extension. Three years per meaningful use stage seems to accommodate providers and vendors much better than two years per stage.

2015 and beyond

Stage 3 of meaningful use will be most affected by the timeline changes. With an extra year to put together a final rule for stage 3, policymakers will be more able to assess stage 1 and stage 2 successes and failures and plan stage 3 accordingly. In addition, EHR vendors will have the option of re-certifying their products to the voluntary 2015 Edition. “We expect the 2015 Edition would be responsive to stakeholder feedback; would address issues found in the 2014 Edition; and would reference updated standards and implementation guides that we expect would continue momentum toward greater interoperability,” said Jacob Reider, acting national coordinator for health IT.

From the beginning, CMS/ONC has tried to keep the meaningful use program smart and aggressive. The original timelines turned out to be too aggressive, so many are applauding CMS for recognizing that and adjusting timelines as we go along. This will allow more practices and hospitals to meet government requirements and avoid penalties.

With a major ICD-10 deadline less than a year away, some are disappointed that there won’t be some meaningful use leeway in 2014. CMS has once again reminded providers to keep their eyes on long-term goals in addition to short-term goals. “The fact that [this] announcement did not address 2014 issues does not imply that no one is listening to those concerns,” said John Halamka, CIO of Beth Israel Deaconess Medical Center and co-chair of the HIT Standards Committee. “Some may complain that they were expecting lunch and dinner but only got lunch. It’s fair to say that lunch comes before dinner.”