Kreofsky questions the need for the proposed voluntary 2015 Edition. "Why wouldn't you push people to use the 2015 Edition?" she asks. These criteria won't come soon enough to be of any use to software vendors struggling to meet the 2014 criteria, and will add another layer of complexity to existing healthcare IT challenges, she says.
"For an organization that upgrades their EHR in the middle of a reporting period, it's incredibly confusing just to manage and keep track of which edition of the criteria you're at, and to have them changing constantly isn't going to help providers and organizations," Kreofsky says.
She also notes that the period for public input into many of these proposed rules will hit next fall, at just the time when the pressure is on to comply with ICD-10 requirements and, for those who attested for Meaningful Use Stage 1 in 2011 or 2012, to migrate to Stage 2.
"It takes a considerable amount of time and energy to review and respond to proposed rules," Kreofsky says.