Groups Comment on Various Meaningful Use Program Proposals
May 28, 2015 in News
Several groups have issued comments on three recently proposed rules for the meaningful use program.
Under the 2009 economic stimulus package, providers who demonstrate meaningful use of certified electronic health records can qualify for Medicaid and Medicare incentive payments.
Comments on the proposed rules for meaningful use Stage 3 and the Office of the National Coordinator for Health IT’s 2015 health IT certification criteria are due May 29.
Meanwhile, stakeholders have until June 15 to comment on CMS’ proposed modifications for 2015 through 2017 (Gruessner, EHR Intelligence, 5/20).
Comments on Meaningful Use Modification Proposal
In April, CMS released a proposed rule that would shorten Medicare and Medicaid meaningful use attestation for eligible professionals and hospitals to a 90-day period in 2015.
Overall, the proposed rule would:
- Realign the reporting period starting in 2015 to allow hospitals to participate on the calendar year instead of the current fiscal year period;
- Reduce the number of meaningful use objectives to improve advanced use of EHRs; and
- Remove redundant measures and those that have become widely adopted.
In addition, the proposed rule would change Stage 2 meaningful use requirements related to patient engagement (iHealthBeat, 4/13).
In a statement, AMA President-elect Steven Stack said, “CMS’ proposal offers common sense solutions that, if finalized quickly, will help more physicians use EHRs in a truly meaningful way while supporting patient engagement.”
AMA also made several recommendations to help bolster meaningful use attestation, including those related to:
- Removing the “pass-fail structure” of the program; and
- Quality measure reporting (Gruessner, EHR Intelligence, 5/22).
The American Academy of Family Physicians in its comments applauded CMS for shortening the reporting period but raised several concerns.
For example, AAFP Board Chair Reid Blackwelder in a letter questioned why CMS planned to terminate Stage 1 of the program with only six months left in the 2015 calendar year.
He said, “This change is likely to cause significant confusion,” noting that CMS should offer resources alongside the final rule to alleviate concerns.
AAFP also cautioned against “unreasonable” and “abrupt” action to advance the meaningful use program. Instead, Blackwelder said CMS should “provide the option for eligible professionals to accelerate their usage every other year” (AAFP News, 5/27).
Comments on Stage 3 Proposed Rule
In March, HHS released proposed rules for Stage 3 of the meaningful use program that aim to offer eligible professionals and eligible hospitals more flexibility.
Under the proposed rule, all eligible professionals beginning in 2018 would report on Stage 3 of the meaningful use program regardless of their previous participation. Providers would have the option to move to Stage 3 starting in 2017 (iHealthBeat, 3/23).
In comments submitted this week, the American Hospital Association said that CMS should delay finalizing the Stage 3 rule until it has more experience with Stage 2, as 2015 is the first year many hospitals will be at that stage, AHA News reports.
AHA Executive Vice President Rick Pollack said, “While the Stage 3 proposals offer promising ideas that could further health information exchange and support greater patient engagement … [t]he transition to new technology supporting Stage 2 has been a challenge for providers due to”:
- A lack of vendor preparedness;
- Insufficient infrastructure to meet information-sharing requirements;
- Requirements to use untested standards; and
- Short timelines.
As such, AHA also recommended that CMS work to develop improved standards and infrastructure to support data exchange (AHA News, 5/27).
CHIME said that as the proposal stands, it “doubt[s] many providers could participate in 2018 successfully.”
Among other things, CHIME recommended that CMS revise the Stage 3 proposal to include:
- A 90-day reporting period for the first year;
- A 90-day reprieve from the program during any year for upgrades, planned downtime, patching software bugs and incorporating new technologies; and
- Hardship exceptions for providers that switch vendors (Walsh, Clinical Innovation Technology, 5/27).
2015 Health IT Certification Criteria Comments
In March, the Office of the National Coordinator released the 2015 Edition Health IT Certification Criteria proposed rule, seeking to better align with the strategy outlined in ONC’s draft Interoperability Roadmap (iHealthBeat, 3/23).
In separate comments, CHIME said that it supported ONC’s approach, but urged the office to keep privacy and security in mind as it finalizes the certification criteria proposal, Health IT Security reports.
CHIME noted that it was “concerned that … patient information will not be easily transferable among providers” if privacy and security “requirements vary significantly.”
CHIME also said that more study and testing should be conducted before ONC finalizes its data segmentation criteria for how EHRs track health information (Snell, Health IT Security, 5/27).