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Groups Offer Comments, Suggestions for MU Modification Proposals

June 16, 2015
by Rajiv Leventhal
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Several healthcare IT groups have submitted comments and offered suggestions in response to the Centers for Medicare & Medicaid Services’ (CMS) proposed meaningful use modifications from 2015-2017 that it laid out earlier this year.

In April, CMS issued a new proposed rule to align meaningful use Stage 1 and Stage 2 objectives and measures with the long-term proposals for Stage 3. The proposed rule would streamline reporting requirements and would shorten Medicare and Medicaid meaningful use attestation for eligible professionals and hospitals to a 90-day period in 2015. Comments for that proposed rule were due on June 15.

For one, the Alexandria, Va.-based American Medical Group Association (AMGA) expressed appreciation “for many of the proposals that ease the burden of reporting requirements for some of the more operationally challenging measures, in addition to formally proposing a 90-day reporting period, instead of a one-year reporting period, for 2015.  AMGA has been advocating for this change since last year. 

“AMGA has always supported the goals of the Medicare and Medicaid EHR Incentive Programs, and our members have eagerly embraced these goals, despite the operational challenges they have presented,” Donald W. Fisher, Ph.D., President and CEO of AMGA, said in a statement. “This proposed rule reflects that CMS has been sensitive to the struggles that the healthcare industry has had with meaningful use by simplifying some of the reporting requirements through 2017, which our members greatly appreciate.” 

Additionally, the Ann Arbor, Mich.-based College of Healthcare Information Management Executives (CHIME) also commended CMS for leading a series of changes to the program, specifically the provision to shorten the EHR reporting period in 2015 from 365 days to 90 days.“The additional time afforded by this modification will help hundreds of thousands of providers meet meaningful use requirements in an effective and safe manner. Further, it will serve as positive incentive for those who optioned alternative pathways to meet MU in 2014 to continue their work in 2015 and beyond,” CHIME said in a statement.

The Chicago-based Healthcare Information and Management System Society (HIMSS) also wrote that it strongly supports the proposal to change the 2015 meaningful use program reporting requirements to any continuous 90-day period within the calendar year.

However, HIMSS also cautioned CMS to ensure that the final 2015 program requirements take into account the timing of the publication of this Final Rule and the complexities for the short turnaround in meeting these requirements before the end of calendar year 2015. It said, “HIMSS encourages CMS to recognize that with the publication of these Final Rules likely to occur in mid-to late summer, providers will be hard pressed to meet any new programmatic requirements in such a short timeframe.  Our overriding concern is continuing to enable providers to utilize health IT in the march toward healthcare transformation, and that is best accomplished by providers remaining as participants in the meaningful use program.  There will be very little time for providers and developers to make any adjustments to their technology and their workflow and get a full 90 days of meaningful use reporting started and completed before December 31, 2015.  We ask that any changes finalized in this rule take in account the tight timeline between Final Rule publication and required implementation dates.”

What’s more, the Consumer Partnership for eHealth, in conjunction with some 50 healthcare advocacy groups, wrote a letter to CMS regarding its proposed reversal of key patient engagement criteria in meaningful use for 2015 to 2017. The groups wrote that they “are dismayed that CMS intends no longer to require that 5 percent of patients view, download or transmit their health information or send a secure message to their providers.  Instead, CMS proposes that doctors and hospitals merely show that just one patient used online access to their health information, and that secure messaging was merely turned on, not whether any patient has actually used it. We are deeply disappointed in CMS’s reversal of these essential commitments to patient and family engagement.”

The letter continued, “Every available piece of survey data shows that 5 percent is more than achievable.  In fact, CMS itself reports that median performance is 32 percent of patients for doctors and 11 percent of patients for hospitals on Stage 2’s measure of actual online access…CMS's proposed amendments constitute a dramatic retreat from essential efforts to make patients  and family caregivers true and  equal partners in improving health through shared information, understanding and decision-making.

Separately, various healthcare advocacy groups recently had several comments and concerns regarding CMS’ Stage 3 proposals. Those public comments were due to the feds on May 29.