Trade groups press CMS for meaningful use changes
The American Medical Group Association, a trade group that represents medical practices and health systems, is the most recent to comment, calling for bolstering the healthcare IT infrastructure to ensure it will support the anticipated increased requirements for data transmission in the years ahead.
In its June 15 letter to CMS, making recommendations on the proposed rule to modify MU in 2015 and through 2017, AMGA said its members are concerned about the increases in compliance thresholds proposed for Stage 3.
"AMGA has always supported the goals of the Medicare and Medicaid EHR Incentive Programs, and our members have eagerly embraced these goals, despite the operational challenges they have presented," wrote AMGA President and CEO Donald W. Fisher. "This proposed rule reflects that CMS has been sensitive to the struggles that the healthcare industry has had with Meaningful Use by simplifying some of the reporting requirements through 2017, which our members greatly appreciate."
AMGA members are appreciative that CMS eased the burden of reporting requirements for some of the more operationally challenging measures, he noted, in addition to formally proposing a 90-day reporting period, instead of a one-year reporting period, for 2015 – a measure that AMGA has advocated since last year.
Pressed for time
HIMSS, meanwhile, cautioned CMS to make sure the final 2015 requirements take into account the timing of its final rule publication, noting in its June 15 letter the short turnaround time, given the deadline for meeting the requirements is the end of this year.
"HIMSS encourages CMS to recognize that with the publication of these Final Rules likely to occur in mid-to late summer, providers will be hard pressed to meet any new programmatic requirements in such a short timeframe," the group asserted. "Our overriding concern is continuing to enable providers to utilize health IT in the march toward healthcare transformation, and that is best accomplished by providers remaining as participants in the meaningful use program."
Moreover, "there will be very little time for providers and developers to make any adjustments to their technology and their workflow and get a full 90 days of meaningful use reporting started and completed before December 31, 2015," HIMSS pointed out. "We ask that any changes finalized in this rule take in account the tight timeline between Final Rule publication and required implementation dates."
Among the points HIMSS highlighted in the letter signed by HIMSS Board Chair Paul Kleeberg, MD, and H. Stephen Lieber, HIMSS president and CEO, are:
- HIMSS strongly supports the proposal to change the 2015 Meaningful Use Program reporting requirements to any continuous 90-day period within the calendar year.
- We caution CMS to ensure that the final 2015 program requirements take into account the timing of the publication of the Final Rule and the complexities for the short turnaround in meeting these requirements before the end of calendar year 2015.
- HIMSS proposes that CMS phase-in new thresholds for the Patient Electronic Access Objective measures that account for the challenges facing some providers in meetng these requirements.
- We encourage CMS to take the same phased-in approach toward secure electronic messaging objective measure thresholds.
[See also: HIMSS presses HHS for big-time changes.]
In a letter submitted to CMS on May 27, CHIME, which represents more than 1,400 healthcare chief information officers, provided CMS with a list of proposed changes to Stage 3 of meaningful use::
- Offer a 90-day reporting period for the first year of Stage 3 compliance, at least for payment adjustment purposes;
- Modify requirements for and retain the 90-day reporting period for providers attesting to meaningful use requirements for the first time, whether in a Medicare or Medicaid context;
- Eliminate patient action thresholds for the care coordination objective;
- Reduce the number of required measures in multi-measure objectives, health information exchange and care coordination;
- Create hardship exceptions for providers switching vendors;
- Allow providers to take a 90-day reprieve during any program year for upgrades, planned downtown, bug fixes related to new technology or optimizing the use of new technology within new workflows; and
- Allow, in limited circumstances, paper-based means to achieve measure thresholds.
[See also: CHIME: Stage 3 rules 'unworkable'.]
Additionally, CHIME praised CMS for shortening the EHR reporting period in 2015 to 90 days, rather than a full year.
"The additional time afforded by this modification will help hundreds of thousands of providers meet meaningful use requirements in an effective and safe manner," CHIME officials wrote. "Further, it will serve as positive incentive for those who optioned alternative pathways to meet MU in 2014 to continue their work in 2015 and beyond."
HIMSS, too, supporting the 90-day reporting period, suggesting that full-year attestation could be an option in 2016.
"Today, too many ,manual processes are required to fill gaps in e-report writing," HIMSS wrote, adding that reporting flexibility i critical while CMS, measure developers, vendors, end users and other stakeholders work to address the issues surrrounding e-reporting.