The HIMSS Electronic Health Record (EHR) Association, an EHR vendor trade group, is looking for speed and clarity from the government on Stage 2 of meaningful use flexibility.
In response to the Centers for Medicare and Medicaid Services (CMS) and the Office for the National Coordinator for Health IT (ONC) notice of proposed rulemaking on Stage 2 flexibility, EHR Association wrote that its important CMS and ONC to clarify text references that refer to providers that can’t “fully implement” 2014 certified electronic health record technology. Instead, EHR Association is asking for language that plainly states the flexibility is for a broadly-based array of challenges. They say that providers should be able to determine their Stage 2 flexibility based for any timing-related reason.
“We believe this simplicity, focused more generally on “timing-related challenges,” will better reflect the proposal’s intention as described in the preamble and by CMS and ONC staff in presentations on the proposed rule,” EHR Association wrote to Karen DeSalvo, M.D., National Coordinator for Health IT and Marilyn Tavenner, R.N., Administrator for CMS. EHR Association is consistent of top-level EHR vendors like GE Healthcare, Allscripts, Cerner, and McKesson.
Ultimately, the association says that simplicity would avoid confusion on what constitutes a delay and what would be sufficient evidence of a delay for auditors. It would ease providers fears about attesting and getting audited, EHR Association writes.
EHR Association also wrote that it is important that CMS and ONC not make any changes that would be problematic for those who have already made decisions based on the proposed rule. The reason is because of timing, and the quickness in which providers have to act to attest.
In May, CMS and ONC proposed a rule that states that providers can use the 2011 Edition of certified electronic health record (EHR) technology (CEHRT) or a combination of 2011 and 2014 Edition CEHRT for the EHR reporting period in 2014 for the Medicare and Medicaid EHR Incentive Programs. In 2015, the rule proposes that hospitals and professionals would be required to report using 2014 Edition CEHRT.
CMS and ONC also included a provision that would formalize CMS and ONC’s previously stated intention to extend Stage 2 through 2016 and begin Stage 3 in 2017. CMS and ONC say these proposed changes would address concerns raised by stakeholders and will encourage the continued adoption of Certified EHR Technology.
EHR Association’s complete comments can be found here.