Various stakeholders have begun taking part in sending their public comments to the Centers for Medicare & Medicaid Services (CMS) with regard to the Stage 3 Meaningful Use proposed rule and the proposed modifications to Stage 2 Meaningful Use requirements for the next few years.
The College of Healthcare Information Management Executives (CHIME) released their comments to CMS about the proposed rulings on May 27. CHIME representatives found that Stage 3 Meaningful Use requirements under the proposed rule are “too ambitious” and need some significant revisions, according to a company press release.
Additionally, the organization showed complete support of CMS in reducing the EHR reporting period in 2015 from a full year to a continuous 90-day period. CMS did reduce the number of objectives under the Stage 3 Meaningful Use proposed rule and improved the reporting periods, but the high number of total proposals for the Stage 3 portion was thought “unworkable” by CHIME representatives.
“Were all requirements finalized as proposed, we doubt many providers could participate in 2018 successfully,” CHIME stated in its public comments. “And with so few providers having demonstrated Stage 2 capabilities, we question the underlying feasibility of many requirements and question the logic of building on deficient measures.”
There are specific steps CHIME offered that may improve attestation to Stage 3 Meaningful Use requirements if CMS integrates the suggestions in the final ruling. These steps are:
1) Requiring a 90-day reporting period under Stage 3 Meaningful Use regulations for the first year of attestation
2) Retain the same 90-day period for any eligible healthcare provider participating in the Medicare or Medicaid EHR Incentive Program for the first time
3) Discontinue patient action thresholds under the patient portal objectives
4) Reduce the number of measures in certain encompassing objectives like health information exchange and care coordination
5) In limited circumstances, give providers the opportunity to meet objectives via paper-based means
6) Give providers a 90-day remission in any calendar year for program upgrades, bug fixes, or EHR optimization
CHIME was especially concerned with “unrealistic” health information exchange measures and the ongoing uncertainties around patient action objectives. CMS proposed that modified Stage 2 Meaningful Use requirements would mandate that only one patient among a provider’s consumer base would need to view, download, and transmit their health data. However, under the Stage 3 Meaningful Use proposed rule, this requirement goes up to 25 percent of the patient population among eligible hospitals and professionals. CHIME was also concerned that attesting to Stage 3 by 2018 was too soon and providers would not be ready.
“While we acknowledge policymakers’ intention to make each Stage more difficult than the last, we are concerned with the strategy that envisions Stage 3 serving as both the apex of MU requirements and as a starting point for those providers with no experience at Stage 1 or Stage 2 of the EHR Incentive program,” CHIME said. “We worry some of the objectives pose too great a stretch for seasoned meaningful users, let alone those who have never participated in the program.”