Recently CMS issued a release postponing enforcement of HIPAA 5010 until Mar 31st 2012. That will be good news to those concerning themselves with enforcement issues. However this delay doesn’t meant that there is a retrieve on the transactions requirement. As a matter of fact CMS issued a clarification where they explain that enforcement is not the same as compliance and that the compliance for HIPAA 5010 Level II remains December 31, 2011. The actual calendar is: Level I Compliance by: December 31, 2010. Level I compliance means “that a covered entity can demonstrably create and receive compliant transactions, resulting from the compliance of all design/build activities and internal testing.” Level II Compliance by: December 31, 2011. Level II compliance means “that a covered entity has completed end-to-end testing with each of its trading partners, and is able to operate in production mode with the new versions of the standards. The problem as I see it is that there are too many changes coming with no time to implement, test and adjust. The EHR incentive requires the acquisition and implementation of a certified EHR and the attestation of Meaningful Use. However there are a number of steps to consider before even meaningful use is achieved. Failure to comply with this requirement at this time means no incentive money. However, jumping too quick to implement without considering all the possibilities will result in significant loss of money, compliance violations, increase stress and quite a handful of frustration. ICD-10 is another challenge looming on the horizon that will take significant resources to comply with. While it will take longer before we face this challenge the same will require preparation in advance. Regardless of the time it takes is another burden on our staff and our Practices at large. Of course another issue we face is the increase legislation, audits and what if feels like constant monitoring of our Practices. Even if we are law abiding citizens we are now spending more in order to remain in compliance with all the new rules and legislation. Regardless at the end of the day it boils down to priorities and resources. Based on that I will recommend the following: Meaningful use means incentive money in the next couple of years; HIPAA 5010 means no money as of January 2012 if you are not compliant. My choice is HIPAA 5010 NOW!!! Dr. Jose Delgado is the President and CEO of Taino Consultants, Inc