- A group of eight hospital associations have joined voices to ask the Department of Health & Human Services (HHS) and Centers for Medicare & Medicaid Services (CMS) to move forward with finalizing proposed changes to meaningful use requirements made earlier this year.
"As organizations representing hospitals and health systems across the country, we are writing to urge the Department of Health and Human Services (HHS) to release, in the immediate future, a final rule making modifications to the meaningful use requirements under the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs for fiscal years (FY) 2015 to 2017," they state in a letter to HHS Secretary Sylvia Mathews Burwell.
CMS first indicated that it was considering reducing meaningful use requirements between 2015 and 2017 earlier this year. In January, Deputy Administrator for Innovation & Quality and Chief Medical Officer Patrick Conway, MD, authored a blog post revealing that the federal agency "intended to be responsive to provider concerns about software implementation, information exchange readiness, and other related concerns in 2015."
CMS did not release the proposed rule in question until April and the proposal has made little progress since then which has drawn consideration from multiple industry associations. Just last week, the College of Healthcare Information Management Executives (CHIME) called on the HHS Secretary to finalize the rule.
Now it is the case that the following eight hospital associations have come together to make a similar request:
- America’s Essential Hospitals
- American Hospital Association
- Association of American Medical Colleges
- Catholic Health Association of the United States
- Children’s Hospital Association
- Federation of American Hospitals
- Premier healthcare alliance
- VHA Inc.
According to these organization, the finalized rule is long overdue:
The rule is past due, given that it will affect the current program year for meaningful use. Indeed, under current rules, meaningful use applies to fiscal year performance for hospitals. FY 2015 ends on Sept. 30 — fewer than 60 days from now. We recognize that the Centers for Medicare & Medicaid Services (CMS) also proposed to change meaningful use reporting for hospitals from a fiscal to a calendar year. Under that policy, the last possible reporting period would begin on Oct. 3. However, the proposed rule also allowed other reporting periods for earlier dates in FY 2015. Even if reporting is moved to a calendar year, hospitals need the certainty of a final rule now to determine the best reporting period to choose and begin the process of reviewing performance and ensuring they have met all of the revised requirements.
That is not to say that these hospital groups are content with the provisions of the proposed rule as is:
Other proposed changes, such as making e-prescribing of discharge medications mandatory or adding new public health reporting measures, however, would make meeting Stage 2 more difficult. And, given the delay in the release of a final rule, they would be virtually impossible for hospitals to accommodate. Hospitals simply will not have sufficient time to understand the new requirements, work with their vendors to purchase and implement new or revised technology that would accommodate them, and invest in the training and work flow changes necessary to meet the new requirements.
With the closing of the fiscal year coming for eligible hospitals at the end of September, the hospital groups are concerned that the delayed release of the final rule would impose burdens on these providers and have far-reaching consequences.
"Widespread failure to meet meaningful use due to unrealistic regulatory requirements and insufficient technology will undermine hospitals’ ability to use EHRs to improve care and involve patients in their care. It will also result in significant financial penalties for the hospital field. Therefore, we urge HHS to release a final rule as quickly as possible," they add.