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AHA and Industry Stakeholders File Final Comments on MU Stage 3 Final Rule

December 15, 2015
by Heather Landi
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The American Hospital Association has urged the Centers for Medicare & Medicaid Services (CMS) to postpone Stage 3 of the meaningful use program until 2019 and until at least 75 percent of hospitals and eligible providers have met Stage 2.

The AHA submitted a letter, addressed to Andrew Slavitt, acting administrator for CMS, as its official comment on the final rule for the Centers for Medicare & Medicaid Services’ (CMS) Electronic Health Record (EHR) Incentive Program – Stage 3 and Modifications to Meaningful Use in 2015 through 2017.

On Oct. 6, the Centers for Medicare & Medicaid Services (CMS) released both the Stage 3 final rule and the Stage 2 modifications final rule together in a 752-page document. Specifically regarding the Stage 3 final rule, CMS announced a 60-day public comment period, which ends today, to facilitate additional stakeholder feedback.

Most health IT leaders responded to the rule with cautious optimism, and many further believed that the required start date of 2018 for Stage 3 is too soon. As previously reported by Healthcare Informatics, the American Academy of Family Physicians (AAFP) has asked Department of Health and Human Services (HHS) Secretary Sylvia Burwell to hit the pause button on the meaningful use program. AAFP has even launched a Speak Out tool to help family physicians demand that their representatives do just that against the MU program.

In its comments filed last Friday, the AHA stated that the nearly 5,000 member hospitals, health systems and other healthcare organizations that it represents strongly support the use of electronic health records (EHRs) and have worked diligently to implement health information technology to improve the quality and safety of patient care.

"However, the complexity of the EHR Incentive Program has required excessive spending and focus on meeting meaningful use criteria; resources that could be better spent on patient care,” Thomas Nickels, executive vice president for AHA, wrote in the letter. “

Specifically, the AHA urges CMS to revise the EHR Incentive Program framework “to reflect program experience to date, provide flexibility in the program measures so that providers can use certified EHRs to support high-quality clinical care and patient engagement, and delay new program requirements until the standards and infrastructure supporting the exchange of health information are mature.”

Regarding revising the framework to reflect experience to date, the AHA recommends a 90-day reporting period be available for the first year of Stage 3 and any subsequent stages, and “whenever there are changes to the definition of certified EHR, including a new edition of technology or new functionality.”

“Specifically, the AHA recommends that providers not be required to begin Stage 3 until at least 75 percent of eligible hospitals (EHs), 75 percent of critical access hospitals (CAHs) and 75 percent of eligible professionals (EPs) have met Stage 2. A requirement to start Stage 3 should not occur in advance of the start of the new physician Merit-based Incentive Payment System (MIPS) and Advanced Payment Model (APM), currently scheduled to begin in 2019. The voluntary start of Stage 3 could be available in 2018,” the letter stated.

The College of Healthcare Information Management Executives (CHIME) issued a statement yesterday calling for a similar extension to the timeline.

CMS also should eliminate the all-or-nothing approach in meaningful use, AHA stated, while also recommending that “physicians and hospitals that attest to meeting 70 percent of the meaningful use requirements be designated as having met meaningful use.”

With regard to providing flexibility in program requirements, the AHA recommends that CMS focus on the availability of mature functionality in certified EHRs rather than thresholds that count the use of functionality.  “AHA recommends CMS modify requirements in Stage 3 to emphasize the availability of EHR functionality, rather than counting the number of times functionality is used,” the letter stated.

And, AHA recommends CMS adopt program requirements supported by mature interoperability standards and infrastructure only. To this end, the AHA recommends that “CMS refrain from including requirements in regulation that providers use a standard or functionality in certified EHRs in advance of evidence that the standard or functionality is ready for nationwide use.”

While the demand for information exchange grows, the AHA also urges CMS to work with federal agencies to prioritize the development of a patient identifier.

The Cleveland Clinic, an integrated health system comprised of 10 hospitals and 20 family health centers, also voice concerns about the direction of the MU program in its comments on the Stage 3 final rule.

“We recognize that the MU program has successfully driven the adoption of EHRs, with over 80 percent of hospitals and physicians now using these systems. We must now turn our attention to ensuring that all of the practices in our respective communities have high functioning technology to achieve interoperability across all care settings. Yet, with the release of Stage 3 set for 2018, we fear the current trajectory of the MU program will hinder efforts to move forward,” Robert White, M.D., associate chief medical information officer for Cleveland Clinic wrote.

“Despite our written comments and concerns and vast experience with Stage 2 of the program, Stage 3 continues to press forward with the current, ineffectual Meaningful Use structure—the one-size-fits-all approach that lacks accommodations for the different needs of our practices and our patients. The Stage 3 Final Rule, like its predecessor rules, is too focused on pass-fail requirements and lacks emphasis on outcomes,” White wrote.

The health system urged CMS to reconsider Stage 3 and refocus instead on the infrastructure needed to promote adoption, enhance interoperability and improve usability. “Delaying the start of Stage 3 and further aligning the timing of this effort with MACRA may perhaps be a more reasonable initial opportunity,” the letter stated.




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