Karen Thomas fully expects Main Line Health to comply with Stage 1 requirements for meaningful use of health information technology this year. But the vice president and chief information officer of the Berwyn, Pa., health system won't be rushing to Washington, D.C., to claim incentive dollars just yet.

"We took our foot off the gas," Thomas says, referring to the health system's original plan to seek funds this year under the American Recovery and Reinvestment Act.

Thomas isn't alone. CIOs across the country are concerned that final rules for Stage 2 won't be released in time to allow for full implementation, which could reduce payouts significantly. For example, hospitals filing for Stage 1 funding by September need full Stage 2 certification by Oct. 1, 2012. But the Office of the National Coordinator may not issue final Stage 2 regulations until the summer of 2012, leaving hospitals scrambling.

"If you start in 2011 and you are not a meaningful user in 2012, you lose a year of payment," notes Chantal Worzala, director of policy at the American Hospital Association. "You can come back and get Year 3 and 4 funding, but Year 2 is gone."

Holding off on applying for funds may buy some time to assess Stage 2 requirements, but it also means CIOs must convince senior managers and boards of trustees that it's a sound strategic—and financial—decision.

Main Line made a calculated decision to wait because even after Stage 2 is finalized, EHR vendors need to update their applications, which further shrinks hospital-implementation windows. Even so, she's maintaining momentum. Main Line will finish Stage 1 implementation this year and conduct an internal three-month validation, all with an eye to formal certification by March 2012.

To help manage expectations, Main Line created electronic dashboards that track ARRA timelines and show what internal steps are complete or need extra attention. "We are focused tactically on the first phase, but strategically on all of the stages," Thomas explains.