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CHIME Comments on Proposed Meaningful Use Stage 3 Requirements

January 14, 2013
by Mark Hagland
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The national healthcare CIO organization weighs in on concerns around vendor business disruption and HIE development

On Jan. 14, the Ann Arbor, Mich.-based College of Healthcare Information Management Executives (CHIME) submitted formal comments to the Office of the National Coordinator for Health Information Technology (ONC), in response to the release of the Health IT Policy Committee’s proposal for Stage 3 of meaningful use under the American Recovery and Reinvestment Act/Health Information Technology for Economic and Clinical Health (HITECH) Act.

In comments that were similar in tone to those submitted to the ONC by the American Medical Association on the same day, CHIME leaders urged the Health IT Policy Committee to recommend thorough evaluations of what has been accomplished thus far in order to set realistic measures and objectives for hospitals in Stage 3 of MU.

“We see no value in setting unrealistic performance thresholds or expectations before current evaluations of what we have accomplished have been taken,” the letter from CHIME said. “[E]very desirable HER-related objective cannot feasibly be met by 2016, nor do we see any value in attempting the rushed adoption of various EHR uses by that time. Instead, verifiable and continuous progress should be the goal.”

In addition, Pam McNutt, senior vice president and CIO at the Dallas-based Methodist Hospital System, and a member of CHIME’s Policy Steering Committee, said that “One of our main messages to regulators is that we shouldn’t look to cram everything into Stage 3. The modernization of America’s healthcare system is a decade-long progression,” McNutt emphasized. “We need to make sure that the HIT Policy Committee is looking at more than just the Stage 2 measures and objectives when making recommendations to HHS [the Department of Health and Human Services]; that’s why we strongly urged thorough evaluations of to-date accomplishments and progress.”

Among the specific recommendations CHIME leaders made were the following: encouraging timeframes for Stage 3 to be “linked to and preceded by proven HIE [health information exchange] capabilities”; ensuring that EHR certification requirements “yield vendor products that allow EPs [eligible providers] and hospitals to fully and easily satisfy any meaningful use documentation and audit requirements”; and, that ONC consider protection or accommodation for hospitals and eligible professionals having to meet MU requirements in the context of EHR vendor business failures and vendor consolidation.

The full text of CHIME’s letter to the ONC can be found at:




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