Earlier this week, we reported on the conflicting sets of recommendations being communicated to the Office of the National Coordinator for Health Information Technology (ONC) regarding stage 2 meaningful use requirements, coming from two different coalitions—one a coalition of medical associations and societies pleading with ONC to make the stage 2 requirements more flexible and less burdensome for physicians; and the other from a coalition of consumer, senior and labor groups asking for the stage 2 requirements to be made more rigorous in key areas.

Now, the Chicago-based HIMSS Electronic Health Record Association (EHRA) has added its voice to the mix, writing a letter to Paul C. Tang, M.D., in his capacity as meaningful use Workgroup Chairman for the Health Information Technology Policy Committee at ONC, essentially asking Dr. Tang to get ONC to slow down some the timeframes around stage 2 of meaningful use and rework some of the elements of the EHR certification program under HITECH (the Health Information Technology for Economic and Clinical Health Act).

Under the subhead “Adopt a Timeline and Schedule That Allows for Safe Development, Certification, and Adoption of Certified EHRs,” the EHRA tells Dr. Tang, “We are very concerned with the current schedule for release of the Final Rule for 2013-2014 meaningful use, and when it will be necessary for eligible hospitals and physicians to be able to implement 2013-2014 certified software. With the time required to develop software, perform adequate quality assurance, obtain ONC-ACB certification, and deploy the software in provider organizations (including internal testing, implementation of new features, and end-user training), currently proposed timelines are simply not sufficient—particularly as regulatory pressures on providers are exacerbated by 5010, ICD-10, and other regulations that will go into effect in the next 24 months.”

Among six key specific recommendations the EHRA makes in this letter are:

• That ONC should “Define Stage 2 with the required level of detailed requirements and technical specifications 187 months in advance of the beginning of Stage 2”;
• That ONC should “Limit Stage 2 to increased adoption of Stage 1 measures”;
• That ONC should establish a “feasibility panel” made up of vendor and provider representatives to review any “new features (including detailed requirements and technical standards)” in order to determine whether such new features are really workable or not;
• That ONC should “Begin Stage 2 in 2014 for the earliest group of adopters,” while extending “2011-2012” certification into “2011-2013” certification, and then collapse the current three two-year stages into two three year stages instead;
• That ONC should shorten the length of the reporting period during the first year of each phase;
• That ONC should “Allow providers earning Medicare incentives to be able to ‘skip a year,’ similar to the Medicaid incentive program.”

The letter goes on to complain that, “During the development of objectives for Stage 1, there was not sufficient detail to begin development until the publication of the Proposed Rule in January 2010.

In some ways, the EHRA’s set of proposals is even more far-reaching than that of the coalition led by the American Medical Association, in that, rather than focusing just on certain requirements (well, a very large range of requirements, in fact), as the medical association’s proposal did, the EHRA is asking ONC to actually redraw its timeframes, and not just inconsequentially, either.

It will be fascinating to see how (if at all) ONC officials respond to this latest salvo. The letter to Dr. Tang certainly packs a punch, as the EHRA represents virtually every healthcare IT vendor of any size (as well as many smaller ones) with an interest in the meaningful use process. And, just as the medical association letter contrasted with that of the Consumer Partnership for eHealth (the coalition of consumer, senior and labor groups), so does the EHRA letter contrast with the consumer group’s communication. What is emerging more and more clearly is a very strong, dynamic tension between the providers and vendors on the one hand, who will have to implement everything under HITECH, and the consumer groups whose interest is in a rapid and comprehensive transformation of the healthcare system and an acceleration in healthcare IT change. Next up? Purchasers and payers. But whose voices will ONC officials give the most weight to? And how much modification will it be possible to make in either direction, going into stage 2? Stay tuned in the months ahead for the answers to emerge.