The government should not move its Meaningful Use program into Stage 2 until it has sufficient time to assess the progress of Stage 1, according to the College of Healthcare Information Management Executives (CHIME), which made the recommendation to the HIT Policy Committee on proposed Stage 2 measures.
"CHIME believes that it would not be prudent to move to Stage 2 until about 30% of (eligible hospitals and eligible providers) have been able to demonstrate EHR MU under Stage 1," the organization's comment letter (PDF) read. "We believe this approach would strike a reasonable balance between the desire to push EHR adoption and MU as quickly as possible, and the recognition that unreasonable expectations could end up discouraging EHR adoption if providers conclude that it will be essentially impossible for them to qualify for incentives."
Providers may seek to qualify for incentives by achieving meaningful use objectives for Stage 1 by Sept. 30, 2012, but legislation establishing the EHR Incentive Program does not lay out hard-and-fast deadlines for initiating the second stage of the program, with its subsequent set of objectives.
CHIME also recommended that CMS/ONC retain the core and menu-set dynamic utilized in crafting Stage 1 measures, but cautioned against adding any requirements to Stage 2 core measures that did not appear in Stage 1 at all.
In response to specific proposed objectives for Stage 2, CHIME recommended CMS:
-- Not require a large number of CDS rules be used: "The goal at this point should not be use of a large number of CDS rules but effective use of a smaller number," CHIME said. "EHR technology should be capable of implementing CDS rules identified as appropriate by EHs and EPs, and MU criteria should not become a 'back door' means for the federal government to interfere with the practice of medicine."
-- Focus on CPOE, not electronic clinician documentation: "We believe it is premature to focus on electronic notes, largely due to a lack of physician readiness," the comments said. "For the foreseeable future, we believe it is much more important to focus attention on CPOE, especially with CDS, than on electronic notes."
-- Provide an opt-out option on the proposed objective for HIE which would require that a provider connect to at least three external providers in a primary referral network. CHIME stated it is "extremely concerned. Whether there is a functioning HIE in an area is totally beyond the control of EHs and EPs. We believe that an EH or EP should be able to opt out of the HIE requirement if reasonable access to an HIE is not possible."