When it comes to the aftermath of the meaningful use Stage 2 final rule, released recently by the federal Centers for Medicare and Medicaid (CMS), EHR vendors find themselves relieved, but still very much under the gun.
Like seemingly everyone else in the health IT industry, vendors reacted positively to the CMS’ decision to delay the start of Stage 2 attestation. The creation of a three-month reporting period, as opposed to the originally proposed 365-day reporting period, for those attesting for the first time in 2014, was met with overwhelming support from Leigh Burchell, vice chair of the EHR Association (EHRA). The EHRA represents various large and small vendors in the industry and is associated with the Healthcare Information and Management Systems Society (HIMSS).
“We’re delighted that CMS finalized the one-year delay in the start of Stage 2, as well as the 90-day reporting period,” Burchell said to Healthcare Informatics. “That was enormous for us as vendors for development, but also for our clients, particularly those large enterprise systems and hospitals, etc. who were very concerned about their ability to execute in a safe way for their preparations for Stage 2 and then train appropriately on the new measures, and the new requirements in time for October of next year. That was a big one, for us. We were certainly pleased with that.”
A few months ago, the EHRA actually wrote a letter to CMS, the Office for the National Coordinator of Health IT (ONC), and the Office of Management and Budget, and submitted comments, expressing its members’ concerns over the requirements for upgrading and implementation by the original dates. Before the final rule, these feelings were prevalent across the industry. Mark Segal, Ph.D., vice president for government and industry affairs at the Oak Park, Ill.-based GE Healthcare IT, said his company had the same concerns as the EHRA.
“Consistent with comments from GE and a number of others, we were pleased that for 2014, providers only have a three-month/one-quarter reporting period. We had been very concerned over the number of folks in or starting meaningful use in 2014; that you are talking about a very large number of upgrades in a very compressed period of time,” Segal said to HCI.
Both Burchell and Segal know that the delay doesn’t mean EHR vendors are off the hook. Burchell noted, for one, EHRA and its members still don’t have all the information they need. She said the clinical quality measure specifications and the certification test scripts are still needed by vendors to assess the impact of the rules on both vendors and providers.
“There is no doubt that we remain in a compressed timeline,” Burchell said. “It’s significantly better than would have been the case if they didn’t allow for that 90-day reporting period. Nonetheless, we have a lot of hard work to do and we’ll have to be creative in how we get it done. But, unequivocally, we’re committed to making it happen and figuring out how to do it.”
Both of these concerns were seconded by Segal, who said even with the year’s additional time, getting the upgrades done is going to be very tight. He also mentioned concerns over the fact there the certification test methods and the specifications for the quality measures weren’t released with the final rule.
“On the test methods, that’s the work product between the certification criteria in the rule and the actual script that we have to work from in order to get our products certified,” Segal said. “The test methods sort of translate the criteria in the rule, which can be fairly brief, into, what are the ways in which ONC wants to convey to a certifying body that we’ve done something. We had really wanted those earlier rather than later.”
Even providers, such as Chuck Podesta, CIO of Fletcher Allen Health Care (Burlington, Vt.), said vendors still have a tremendous burden. Considering the CMS kept a lot of criteria in certification, he doesn’t see how vendors with a large client base can logistically get those upgrades done by 2014.
Burchell said there are additional challenges beyond the time crunch. There is new product functionality that was not required in Stage 1. For instance, she said, there are requirements to incorporate and combine data after receipt of structured documents with clinical decision requirements, and make that data actionable. She said this is a change in the way data is processed and turned around. While the ultimate goals from this requirement are valuable, she said, it will require “an area of effort” from vendors.
Despite the time crunch and upcoming challenges, the EHR vendors came out with a positive view of the final rule. Even things like the lack of test methods, Segal said, was countered by the ONC’s guidance in certain areas. “They would say, we expect our test methods for this measure would require you to do X, Y, or Z,” he noted.
Beyond the timeline change, there seemed to be other positive outcomes of the final rule, from an EHR vendor perspective. The EHR Association, Burchell said, was supportive of CMS and ONC’s decision to evolve standards-based interoperability, adding that the EHRA continues to analyze requirements around inter-vendor exchange. She also said EHR vendors are also pleased with CMS and ONC moving forward and focusing on structured data, and patient engagement.
Summing it up, Segal said, “In a number of areas, CMS and ONC made things more manageable, reducing the number of final quality measures from what had been proposed, and in some cases thresholds lower than what they had proposed. I think they took steps to make things more workable for Stage 2.”