Meaningful Use Stage 2 Extension, MU Stage 3 Delay and New 2015 EHR Edition Certification Proposed

The big news of the week just came out of CMS at 4 PM EST on a Friday. Feels like they’re trying to bury the news story, but maybe it was just the way the timing worked out. Either way, there’s no way anyone who lives in the EHR and meaningful use would miss the announcement (not to mention I’ve already seen it posted on every major health IT news site). CMS is proposing an extension of meaningful use stage 2 another year through 2016 and so that means a delay in meaningful use stage 3 until 2017.

Here’s how Robert Tagalicod, Director, Office of E-Health Standards and Services, CMS and Jacob Reider, MD, Acting National Coordinator for Health Information Technology, ONC described the change in meaningful use timeline:

Under the revised timeline, Stage 2 will be extended through 2016 and Stage 3 will begin in 2017 for those providers that have completed at least two years in Stage 2. 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 in Stage 2; and second, to utilize data from Stage 2 participation to inform policy decisions for Stage 3.

The phased approach to program participation helps providers move from creating information in Stage 1, to exchanging health information in Stage 2, to focusing on improved outcomes in Stage 3. This approach has allowed us to support an aggressive yet smart transition for providers.

Meaningful Use Stage 2 and 3
This shouldn’t come as a surprise to many. In fact, we’d been discussing the possible meaningful use stage 2 extension in the comments of my post: ICD-10 will be delayed. We thought meaningful use delay was possible, and now it’s happened.

I do like that this delay gives CMS and ONC more breathing room to know what to include in meaningful use stage 3. Plus, maybe they’ll get the MU Stage 3 certification requirements out in plenty of time for EHR vendors to be able to update their software.

One thing that is really interesting about this delay is that meaningful use stage 3 won’t go into effect until after the Medicare EHR incentive money is over. The Medicare EHR incentive money is only scheduled to be paid through 2016. Medicaid wasn’t implementing MU stage 3 until year 6, so I expect there’s no change there. While you won’t have to show MU stage 3 for Medicare EHR incentive money, you will have to attest to meaningful use stage 3 in 2017 if you want to avoid the EHR penalties (Payment Adjustments if you prefer CMS’ terminology). In 2017, those EHR penalties will be at 3%.

Many have called for a delay to meaningful use stage 2 as well, but that didn’t happen today.

2015 Edition EHR Certification
The other part of the CMS announcement is the 2015 Edition EHR certification. They propose having an additional 2015 EHR certification that sounds like it would amount to an update to the 2014 edition. The 2015 edition would fix any issues with the 2014 edition and update any changes to interoperability standards. Sounds like an EHR certification patch.

The catch is that EHR vendors that are 2014 Edition EHR certified wouldn’t have to do 2015 Edition. This is good since we don’t need software vendors having to certify again (as much as certifying bodies would love the new revenue). Although, I won’t be surprised if most EHR vendors take the new standards in the 2015 edition and update their software to those standards. Let’s just hope that if they choose to do so, it doesn’t kill their 2014 Edition EHR certification. We should all be using the latest and greatest standards. Even more important, we need to all be on the same standard.

What do you think of the announcement? I look forward to hearing your thoughts in the comments.

See Also:
HIMSS Response – HIMSS Supports Stage 2 Extension
CHIME Response – Meaningful Use Timeline Shift Does Not Afford Flexibility in 2014

About the author

John Lynn

John Lynn

John Lynn is the Founder of the, a network of leading Healthcare IT resources. The flagship blog, Healthcare IT Today, contains over 13,000 articles with over half of the articles written by John. These EMR and Healthcare IT related articles have been viewed over 20 million times.

John manages Healthcare IT Central, the leading career Health IT job board. He also organizes the first of its kind conference and community focused on healthcare marketing, Healthcare and IT Marketing Conference, and a healthcare IT conference,, focused on practical healthcare IT innovation. John is an advisor to multiple healthcare IT companies. John is highly involved in social media, and in addition to his blogs can be found on Twitter: @techguy.


  • Let me be blunt and pejorative

    This is likely the beginning of the end of meaningful use. The idea of centrally mandated software is detrimental to the tremendous need for innovation in healthcare related software that we so desperately need.

    EHRs are document repositories, and as such are useful in letting multiple providers review free text notes and reports from multiple locations. This has value.

    The next step of collecting and organizing structured data and producing specialist specific interfaces that enhance workflow is beyond the capabilities of EHR vendors. That should be left to the specialists in that area. The government anointing them as experts in this area is ludicrous.

    The government can continue to mandate the use of document management systems (EHRs that do not require the use of poorly designed interfaces to collect inadequate structured data) and mandate use of structured data exchange standards, but beyond that should get out of the way of innovation. Letting meaningful use die on the vine (Which seems to be what is happening) is a good first step.

  • CHuddle,
    In this announcement they didn’t address this issue at all. Although, from the link it seems to say that even if you’re attesting to MU stage 1 in 2014, you still need to use a 2014 Edition certified EHR.

    It’s worth noting that MU stage 2 hasn’t been delayed. I’ve got a post planned for Wed which has a great chart showing the timeline for MU stages based on when you first attest.

  • Sorry, but I find this all really confusing (not your article, the proposed ruling). From what I understand this is NOT a delay of MU in 2014. All 2014 certification and attestation deadlines are still in place. So, if we began Stage 1/Year one in 2012 for three months, run Stage 1/Year 2 for all of 2013, we still have to do three (calendar)months of Stage 2 year 1 in 2014. Correct? At first I thought this was a great way to allow smaller practices to try to absorb the impact of getting ready for ICD-10, but it appears it is no more than an adding an additional year to stage 2 delaying stage 3 to 2017. Frankly, we need the delay next year to attempt to mitigate our ICD-10 impact. I guess it is too much to hope that we can extend Stage 1 another year. Stage 1 to 2 is major jump for smaller specialized practices and trying to deal with that and the major impact of ICD-10 in the same year is next to impossible given our resources. Sadly, I guess it is too much for anyone to realize that.

  • @Natalie
    It appears any delay is still a proposal.

    On your MU stage timing, you are correct, so:
    If your initial Stage 1 attestation was in 2011, you’ll then do Stage 2 in 2014 (yes 3 years of stage 1)

    For all other years you’ll do 2 years of Stage 1, then Stage 2.
    The first year of each stage (so far) is “merely” a 90 day window.

  • I don’t see them ever doing a delay to MU stage 2. Hospitals already started it in Oct 1. I don’t see ONC adding another MU stage 2 delay. I think it’s happening along with ICD-10. Certainly a challenge to do all the various government requirements.

  • […] As I begin the 2014 Meaningful Use measures readiness assessment and vendor cat-herding exercises, I’m reflecting on this portion of CMS’s Director of E-Health Standards and Services, Robert Tagalicod and the ONC’s Acting National Coordinator Jacob Reider’s statement regarding the Meaningful Use timeline modification: “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 in Stage 2.” (Previously published on […]

  • […] Meaningful Use Timelines The most important thing many organizations need to remember is the various timelines for each meaningful use stage. This can be pretty complex because it changes based on when you first attest to meaningful use. Plus, last Friday CMS announced an extension to meaningful use stage 2 and a delay of meaningful use stage 3 for one year. […]

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