- The American Hospital Association (AHA) recently submitted a letter to CMS requesting reduced administrative complexity as a way to save healthcare providers billions in annual costs, including the cancellation of Stage 3 Meaningful Use.
AHA outlined 29 recommendations to reduce regulatory burden in response to the federal organization’s request for information regarding CMS flexibilities and efficiencies
“The regulatory burden faced by hospitals is substantial and unsustainable,” opened AHA. “As one small example of the volume of recent regulatory activity, in 2016, CMS and other agencies of the Department of Health and Human Services (HHS) released 49 hospital and health system-related rules, comprising almost 24,000 pages of text.”
AHA’s response included the following seven recommendations relating to EHR reporting requirements:
1. Cancel Stage 3 of the “meaningful use” program.
“These excessive requirements are set to become even more onerous when Stage 3 begins in 2018,” wrote AHA. “They also will raise costs by forcing hospitals to spend large sums upgrading their EHRs solely for the purpose of meeting regulatory requirements.”
To reduce costs, AHA suggested CMS should instead establish a 90-day reporting period in future years of the program. Additionally, CMS could gain insight from stakeholders regarding how to further reduce the burden of the meaningful use program.
2. Suspend electronic clinical quality measure (eCQM) reporting requirements.
“Hospitals have spent significant time and resources to revise certified EHRs to meet CMS’s eCQM requirements for 2016, with no benefit for patient care,” stated the association. “The AHA urges the Administration to suspend all regulatory requirements that mandate submission of electronic clinical quality measures.”
3. Use only measures that truly matter.
“Public transparency regarding hospital and other provider quality would be supported by thinking strategically about the information most useful to the public,” wrote AHA.
The association stated CMS should work stakeholders—including AHA—to determine which measures most efficiently provide patients with an accurate sense of the quality and safety of different healthcare organizations to eliminate superfluous data.
4. Remove faulty hospital quality measures.
“We urge the Administration to remove all IQR and OQR measures added to the programs on or after Aug. 1, 2014,” wrote AHA. “These measures also should be removed from CMS pay-for-performance programs, such as readmissions and hospital value-based purchasing.”
5. Eliminate unfair long-term care hospital (LTCH) regulation.
“With the implementation of site-neutral payments for LTCHs, which began in October 2015 (as mandated by the Bipartisan Budget Act of 2013), the LTCH “25% Rule” has become outdated, excessive and unnecessary,” stated the association. “As such, we strongly endorse the agency’s recent proposal to implement a 12-month moratorium on the full 25% Rule, beginning October 2017, and again urge the agency to permanently rescind the unnecessary 25% Rule.”
6. Postpone and re-evaluate post-acute care quality measure requirements.
“Recent laws and regulations are rapidly expanding the quality and patient assessment data reporting requirements for post-acute care providers,” wrote AHA.
The association recommended CMS suspend post-acute care quality reporting requirements that were finalized on or after August 1 of 2015 in an effort to reduce regulatory burden providers. Additionally, AHA suggests CMS collaborate with providers working in the post-acute care community to develop more appropriate, valuable requirements in the future.
7. Undo agency over-reach on so-called “information blocking.”
“The AHA urges the Administration to remove the second two attestations, keeping only the statutory requirement that hospitals did not knowingly or willfully take action to limit or restrict the compatibility or interoperability of their EHRs,” wrote the association.
Along with the above recommendations, AHA also issued suggestions for CMS to adjust regulations to account for socio-demographic factors, to allow flexibility for providers sharing treatment space to improve patient access to care, and to expand Medicare coverage of telehealth services.