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Recapping Recommended Changes to Meaningful Use Requirements

Many more recommendations comprise the letters from industry groups to CMS, but a consensus is growing more steadily for some changes to meaningful use requirements.

- The American Health Association (AHA) is the latest industry group to share its recommendations for changes to meaningful use requirements following the publishing of modifications to Stage 2 Meaningful Use and requirements for upcoming Stage 3 in October by the Centers for Medicare & Medicaid Services (CMS).

AHA seeks changes to meaningful use requirements

While numerous industry groups have now registered their concerns about the EHR Incentive Programs in separate letters to the federal agency, they share much of the same vision about the changes necessary for ensuring the ongoing success of meaningful use.

As a result, it's worthwhile in light of the AHA's most recent comments to recap the similar recommendations made by these industry groups representing large constituents of healthcare organizations and professionals.

Adopting 90-day reporting period

AHA joins the College of Healthcare Information Management Executives (CHIME) and Healthcare Information Management Systems Society (HIMSS) in calling for a 90-day reporting period for Stage 3. Echoing CHIME, the former contends that the first year of any stage requires considerable buildup and preparation.

"Experience to date indicates that the transition to new editions of certified EHRs is challenging due to lack of vendor readiness, the necessity to update other systems to support the new data requirements, the mandate to use immature standards, an insufficient information exchange infrastructure and a timeline that is too compressed to support successful change management," AHA Executive Vice President Thomas P. Nickels states.

Postponing the start of Stage 3

Neither AHA nor CHIME wants the next stage of the EHR Incentive Programs to begin prior to 2019. For its part, the former is seeking alignment between meaningful use requirements and those likely to come out of the Medicare Access and CHIP Reauthorization Act (MACRA).

Both organizations have pointed to provider struggles with previous stages of meaningful use as proof that the program's timeframe does not reflect experience-to-date of eligible hospitals and professionals whose success in Stage 1 did not carry over into Stage 2.

"All providers require sufficient time to implement and upgrade technology and optimize performance before moving to more complex requirements for use," adds Nickels.

Eliminating all-or-nothing approach

The American Medical Association (AMA) was likely the first industry group to advance this notion, but it now has company.

AHA, CHIME, and the aforementioned organization all seek the removal of the all-or-nothing thresholds required by the EHR Incentive Programs. AHA goes so far as to set the bar at 70 percent for EPs and EHs in successfully demonstrating meaningful use.

Reducing reporting burden on providers

Here AMA and CHIME are in agreement. The former was much more explicit in calling on CMS to allow providers to get the most out of the data they already have that can be used for the EHR Incentive Programs, Alternative Payment Models (APMs), and the Merit-based Incentive Payment System (MIPS).

Advancing interoperability

AHA, CHIME, and AMA all agree that Stage 3 needs to play a significant role in advancing interoperability and therefore must change significantly in order to do so.

For AHA, it's about use cases. "Prioritization of use cases that accelerate the exchange of the current meaningful use data set that is being captured to support care will build confidence and support for tackling the capture and exchange of additional data elements," writes Nickels.

Echoing AMA, the organization emphasized the need for more time for the healthcare and health IT community to address the issue. "The AHA urges CMS to allow the current market pressures for information exchange from consumers and from new care delivery models to accelerate demand for information exchange," added Nickels.

Many more recommendations comprise the letters from these industry groups to CMS, but a consensus is growing more steadily for some changes.

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