In comments submitted Friday, June 27 on proposed “Modifications to the Medicare and Medicaid Electronic Health Record Incentive Programs for 2014,” the College of Healthcare Information Management Executives (CHIME) offered general support of program changes, but requested additional revisions and clarifications to maintain momentum of the federal initiative.
Comments from the professional association of healthcare CIOs and IT leaders said additional flexibility is needed because changes proposed for the Meaningful Use incentive program were only first released in late May, limiting the amount of time providers have to react to changes.
“CHIME supports the new pathways as defined in the proposed rule,” the letter read. “We believe these options will provide needed flexibility for EHR optimization, encourage continued participation in the program and help maintain the upward trajectory of EHR adoption in the US.”
One of CHIME’s primary requests is that the Centers for Medicare & Medicaid Services allow providers to choose any three-month quarter for an EHR reporting period in the next federal fiscal year or calendar year to qualify for Meaningful Use in 2015. As currently structured, the program requires providers to report a full year of data to qualify for incentives.
“We believe this change will have a dramatically positive effect on program participation and policy outcomes sought in 2015,” CHIME’s comments noted. “The additional time afforded by this modification would help hundreds of thousands of providers meet Stage 2 requirements in an effective and safe manner.”
“We are grateful for the agencies’ acknowledgement that 2014 has been an extremely challenging year for the industry,” said CHIME President and CEO Russell P. Branzell, FCHIME, CHCIO. “The new pathways created by this NPRM will enable many hospitals and physicians to capitalize on progress made to date. However, the benefits of this new flexibility will be immediately lost if 2015 reporting requirements are not tempered. Carrying forward the 2014 policy requiring providers submit data covering one quarter of their choosing in 2015 is common sense.”
Additional flexibility is needed because of the continued industry-wide strain to implement information technology in time to meet ongoing requirements of the program, CHIME contended. “Because there is such limited capacity for the industry to absorb ongoing technology upgrades and process changes, CHIME implores CMS to allow 3-month quarter EHR reporting options in 2015.”
CHIME’s comments also asked that the agencies delete ambiguous attestation requirements related to the definition of “fully implemented” Certified EHR Technology (CEHRT). “A number of CHIME members have indicated their apprehension to take advantage of the new pathways created by this NPRM (because of) how this proposed rule defines ‘full implementation’ of CEHRT since the examples do not adequately represent their situation,” CHIME stated.
“Given the industry’s experience with Meaningful Use audits, there is a lot of anxiety over how such a requirement would be validated,” said CHIME Board Chair Randy McCleese, FCHIME, LCHIME, CHCIO, Vice President of Information Services and CIO at Moorhead, Kentucky-based St. Claire Regional Medical Center. “The fear generated by meaningless audits can be crippling for small and rural organizations like ours. Ambiguity in what constitutes ‘full CEHRT implementation’ defeats the primary intent of this NPRM – namely, to encourage continued participation in the program.”
Overall, CHIME believes “these new pathways will provide much-needed relief to hundreds of thousands of providers struggling to meet MU requirements in 2014, due to circumstances beyond their control,” but CHIME is asking agencies to “explicitly state its intentions to let providers meet MU requirements retrospectively in 2014, if they are able.”
Finally, CHIME offered its support of the one-year extension of Stage 2 for providers that first qualified as meaningful users of EHR technology in 2011 and 2012. “This is a necessary extension to give policymakers time to evaluate past experience and incorporate lessons learned into the third Stage of Meaningful Use,” CHIME stated.
“From Day One, CHIME has been an adamant supporter of Meaningful Use, and we remain supporters to this day,” said Branzell. “Our comments and recommendations are pragmatic and meant to ensure that industry, government and taxpayer investments are properly managed. We are confident that if CMS makes these common sense changes, we can realize the benefits of a modern, connected healthcare system.”
The College of Healthcare Information Management Executives (CHIME) is an executive organization dedicated to serving chief information officers and other senior healthcare IT leaders. With more than 1,400 CIO members and more than 130 healthcare IT vendors and professional services firms, CHIME provides a highly interactive, trusted environment enabling senior professional and industry leaders to collaborate; exchange best practices; address professional development needs; and advocate the effective use of information management to improve the health and healthcare in the communities they serve. For more information, please visit www.cio-chime.org.