- The EHR Association (EHRA) recently submitted a letter to CMS requesting the federal agency align technology requirements of new payment models with requirements related to certified EHR technology (CEHRT). The CEHRT requirements need to be better aligned to ease the current burden on health IT companies, EHRA said.
The letter came in response to a CMS request for information (RFI) to assist in establishing a new direction for the Center for Medicare & Medicaid innovation Center (CMMI).
“Because of the foundational nature of health IT in payment model development and implementation, it is important that healthcare providers and organizations have access to the technology needed to participate,” stated EHRA in submitted comments.
“One way to facilitate this is to harmonize the technology requirements of new payment models with the requirements related to certified EHR technology (CEHRT) already incorporated into other programs, such as Advanced Alternative Payment Models (Advanced APMs) and the Merit-Based Incentive Payment System (MIPS),” the association added.
EHRA urged CMS to align technical needs for payment programs and CEHRT criteria. This would be better than requiring different prescriptive functional requirements to ease burden on health IT companies when developing new features and implementing features into consumer systems.
“For example, Medicare Shared Savings Program participants only need to use a certified EHR, and were not required to adopt additional certified functionality,” noted EHRA. “This alignment with pre-existing programmatic requirements promotes adoption amongst providers and allows health IT vendors to scale development efforts.”
Allowing for better alignment between payment programs and certification requirements would also ease provider burden by reducing the amount of time and money spent to train staff members on using new technologies.
“In preparation for these changes and throughout the development of new models, the Association encourages CMS to collaboratively engage with health IT developers to ensure that the technology we are delivering to providers aligns with the needs of the models,” stated EHRA.
The American Medical Informatics Society (AMIA) also submitted a response to the CMS RFI on shaping the new direction for CMMI.
AMIA advised CMS to consider ways it can provide innovative support – not merely financial support – to developers in an effort to transform care delivery.
“AMIA recommends CMMI consider ways it can serve as a clearinghouse, or platform, of innovation to avoid waste in having separate organizations discover innovations independently,” stated AMIA.
AMIA suggested CMMI could be used as a way of disseminating best practices and education models throughout the industry.
Additionally, CMMI could provide funding for shared informatics tools that can be used by any EHR or health information exchange (HIE) system. Informatics tools could include clinical decision support services, tools for population health, and social determinants of health in clinical care, chronic care management, and care coordination.
As part of this recommendation, AMIA also proposed CMS try to adopt or apply program stability to allow for the development of pilots and test models meant for long-term innovation and use. Long-term projects would allow time for the innovation to spread and scale.
AMIA also recommended CMI leverage new models to further promote the use of informatics in patient care delivery.
“CMMI could achieve this goal through direct funding and enhanced application requirements,” stated AMIA.
AMIA explained its members are willing to assist CMS to review and recommend specific enhancements to potential new model applications.
These responses follow two letters submitted for the CMS RFI by the American Hospital Association (AHA) and HIMSS.
In its letter, AHA stressed the importance of focusing future CMMI projects on improving health data exchange and enabling regulatory relief, among other industry priorities.
Meanwhile, HIMSS urged CMS to focus future projects on expanding opportunities for participation in advanced APMs, consumer directed-care, and market-based innovation models, among other priorities.