MGMA Calls For Moratorium on Stage 2 Meaningful Use Penalties

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Providers who purchased an electronic health record (EHR) system that has not yet been certified for Stage 2 of the Meaningful Use incentive program are in a fix and it is unfair to penalize them for not meeting Stage 2 requirements says the Medical Group Management Association (MGMA).

In a letter to U.S. Health and Human Services (HHS) Secretary Kathleen Sebelius, MGMA President and CEO Susan Turney, MD, MS, FACMPE, FACP, explains that there are currently more than 2,200 products and nearly 1,400 “complete EHRs” certified under the 2011 Meaningful Use criteria for eligible providers in the ambulatory setting. However, among these, there are only 75 products and 21 “complete EHRs” certified for the Stage 2 Meaningful Use criteria.

This means that providers who purchased one of the many products or complete EHRs that are not yet certified for Stage 2 have no way to meet those requirements other than to hope that their vendor will be able to get the necessary product upgrades ready in time, or to replace their entire system with one of the few products or complete EHRs that have been certified as meeting Stage 2 requirements.

Since there was not way for providers to know which vendors would be ready for Stage 2 when they originally bought their EHR systems, it is unfair to penalize them for not meeting Stage 2 requirements by 2015, Turney points out in the letter.

"[Eligible providers (EPs)] who invested considerable resources in their Stage 1 certified EHR, many of them in small or rural clinical settings, are now in danger of falling behind,” Turney wrote. “To avoid the Medicare payment adjustments, EPs would be required to 'rip and replace' their existing EHR with one certified for the Stage 2 criteria. This is an unrealistic and unreasonable demand as the cost to the practice would be prohibitive and the disruption to organizational workflow and patient care would be significant.”

Turney asked CMS to extend the reporting period for both Stage 1 and Stage 2 incentives, survey EHR vendors about when they would be ready and build more flexibility into the Stage 2 reporting requirements.