- The American Medical Informatics Association (AMIA) recently submitted comments supporting a CMS proposed rule that impacts hospital implementations of certified EHR technology.*
Editor's note: Portions of this article have been updated to make clear the proposed status of the CMS rule.
In the letter addressed to CMS Administrator Seema Verma, AMIA especially agrees with the federal agency’s proposals to modify the 2015 CEHRT implementation timeline to reduce stress and administrative burden on providers as part of the FY 2018 Hospital Inpatient Prospective Payment Systems.
In addition to 2015 CEHRT timeline changes, the FY 2018 Hospital IPPS proposed rule reduces quality measures in federal reporting requirements and includes additional reporting period flexibilities.
AMIA supports the federal agency’s proposition to lessen the stringency of electronic quality measures (eCQMs) necessary to comply with the Hospital IQR Program and Medicare EHR Incentive Program.
The association also agrees with plans for reducing reporting periods for both federal programs to two self-selected quarters in 2017 and the first three quarters of the year in 2018 for those reporting electronically.
CMS seeks to change the 2018 EHR reporting period from a full calendar year to a continuous 90-day period for new and returning Medicare and Medicaid EHR Incentive Program participants.
“Generally, AMIA is supportive of the proposed flexibilities afforded to providers for quality reporting and quality payment programs, for example the 90-day EHR Incentive Program reporting period, and reduction of required quality measures,” AMIA stated.
“Given the need to upgrade to the 2015 Edition Certified EHR Technology, and the changing requirements associated with the program in 2018, we anticipate that providers would benefit from additional time to implement, test and adjust workflows,” the association continued. “Likewise, the reduction of eCQMs will better enable hospitals to work towards the goal of more efficient and seamless electronic collection and submission of quality measures.”
While AMIA largely agrees with CMS proposals, the association further suggests CMS allow the use of any two quarters in 2018 for hospitals to retain the ability to reuse data extraction processes in 2018 that were also used in 2017.
Permitting hospitals to use similar data extraction processes in 2018 as in 2017 gives hospitals increased flexibility and more time to properly upgrade and implement 2015 CEHRT.
AMIA also added that the use of any two quarters should apply to the 2018 Medicare and Medicaid EHR Incentive Programs as these programs still require CEHRT to aggregate applicable data and generate CQM results for attestation.
Additionally, the association supports CMS’s proposal to uphold requirements mandating EHR technology be 2015 CEHRT for CQM reporting as the present timeline promotes sustained resources on IT-enabled care delivery.
“Improvements to the 2014 Edition, in terms of functionality and capability, need to propagate across the industry, and evidence suggests government-imposed incentives will increase the likelihood this occurs more uniformly,” stated the association.
As part of its proposed rule, CMS made a request for information regarding ways to reduce burdens on hospitals, physicians, and patients to improve quality of care, decrease costs, and optimize clinical decision making.
In response, AMIA issued the following recommendations:
- Use data reporting requirements to learn, not simply to grade.
- Continue to require use of certified EHR technology to participate in incentive programs.
- Focus on defining clear, expected outcomes, rather than prescriptive process measures.
- Engage organizations and experts to perform scientifically rigorous, peer-review studies to determine which requirements should be retained in future years.
- Develop feedback loops that are accurate, timely and meaningful.
“It’s vital that the industry continue its march towards modernization,” said President and CEO of AMIA Douglas B. Fridsma. “APIs and other key aspects of the 2015 Edition will help improve care through improved interoperability and better patient access to their data.”