The difficulty between what it takes to achieve Stage 1 and Stage 2 is so great, it could easily catch some providers off guard, says Laura Kreofsky, principal advisor at Naperville, Ill.-based Impact Advisors, who specializes in meaningful use. There could be a fair amount of hospitals and eligible providers that will fall short of achieving meaningful use Stage 2, she warns.

“Stage 1 is tough but not too tough. Stages 2 and 3 are darn tough,” Kreofsky says. By making Stage 1 so much easier than Stage 2, in some ways, CMS has set a false sense of security for providers.

[See also: EHR incentive payments surge to $13.7B.]

Most organizations that are concerned about penalties are those driving toward their first year of meaningful use. However, providers have to be demonstrating well in advance of 2015 to avoid penalties. After the first year of MU, some organizations could receive incentives for the current year but be penalized for a previous year. “There are some weird scenarios here,” Kreofsky explains.

Jason Fortin, senior advisor at Impact Advisors, travels nationwide with Kreofsky giving lectures on meaningful use. He said they are familiar with the concerns many hospitals and eligible providers have, but even more telling are the results of a survey that shows the majority of hospitals and eligible providers deferred a transitions of care measure in Stage 1 that will be required in Stage 2.

Fortin and Kreofsy warn that the transitions of care measure is going to be the most difficult part of achieving Stage 2.

In addition, “many thresholds will increase significantly in Stage 2,” Kreofsky says. The first challenge is going to be for providers who have gotten used to performing at one level in Stage 1, to not forget that the percentages will increase for them in Stage 2.

In addition to transitions of care, Kreofsky predicts public reporting and patient engagement will also be the “big gotchas” for Stage 2.

There will also be fewer choices on the menu and a smaller set of measures that can be deferred, Fortin says. 

[See also: EHRA critiques GOP’s MU reboot plan.]