CHIME, which represents more than 1,400 health CIOs and other senior healthcare IT leaders, submitted its comments on the proposed rules for Stage 2 Meaningful Use in a letter dated April 30, which was sent to both CMS and the Office of the National Coordinator for Health IT (ONC).
As CHIME's members continue to apply for incentive payments under CMS's EHR Incentive programs, the organization has called for the federal agency to allow providers to demonstrate Meaningful Use during a continuous 90-day EHR reporting period for their first payment year of Stage 2, similar to the approach used in Stage 1.
[ The AHA also wants to see adjustments made to MU Stage 2 requirements. Read more at AHA Fights Meaningful Use Stage 2 Timing, Scope. ]
"To allow adequate time for application development, provider adoption and testing, CMS should follow the precedent set in Stage 1," the letter said. "The proposed rule would continue the policy set in Stage 1, which allows any continuous 90-day EHR reporting period during the first year of payment, followed by a 365-day EHR reporting period in subsequent years," Jeffery Smith, CHIME's assistant director of advocacy, told InformationWeek Healthcare.
While CIOs welcomed last December's announcement of a delay in meeting new standards for Stage 2 to Fiscal Year 2014, CHIME believes a 90-day EHR reporting period would give providers between Oct. 1, 2013 and July 1, 2014 to meet Stage 2 MU.
"Even in the best-case scenario, we are unconvinced that newly certified technologies would be widely available before Jan. 2013--this leaves 9 months to a year for more than 100,000 providers to adopt, implement, and use new technology," Smith said.
Addressed to Marilyn Tavenner, CMS's acting administrator, and copied to Farzad Mostashari, ONC's National Coordinator for Health Information Technology, the letter also outlines CHIME's concerns on the challenges involved with clinical quality measures (CQM).
CHIME pointed out, for instance, that during Stage 1, certified EHRs were automatically producing CQM reports, but that "the data was inaccurate and largely incomparable across different providers." As part of Base EHR certification, CHIME urged ONC to require EHR products be certified to satisfy all CQMs needed to meet Meaningful Use in each setting--inpatient and ambulatory. "The accurate reporting of quality measures is one of the most daunting challenges faced by providers today," CHIME said.
The letter also asserts that "certification should include all CQMs for associated settings. And in order to minimize the costs of development and implementation, we recommend that ONC work with CMS to limit the total number of CQMs associated with each setting."
To ease the path by which healthcare providers can meet Meaningful Use Stage 2 requirements, CHIME also made recommendations on all 42 proposed objectives for eligible clinicians, hospitals, and critical access hospitals that focused on a variety of issues.
For example, CHIME opposes the Meaningful Use Stage 2 proposal that hospitals should record their patients' family health history as structured data. According to CHIME, this is an "inappropriate" measure for hospitals to perform. Additionally, hospitals do not possess sufficiently mature standards that would allow for the collection of structured data for this measure.
Another proposal calls for hospitals that transition or refer patients to another care facility or provider to prepare a summary of care record. At least 65% of these transactions should be completed and sent electronically. CHIME said the threshold should be reduced to 50%. "Among other things, a lower threshold would recognize that large numbers of potential recipients may not be prepared or willing to accept a summary care record electronically," the letter said.
With regard to medical images, which are to be made accessible in EHRs under the Meaningful Use Stage 2 requirements, CMS proposed that more than 40% of all scans and tests whose result consists of one or more images ordered by the an provider during the EHR reporting period be retrieved through an EHR.
According to CHIME, this proposed measure is unachievable for many physician practices, especially smaller, independent practices or those whose patients use multiple imaging centers. Furthermore, CHIME's letter urged CMS to clarify which scans and tests would be acceptable. "For example, would an electrocardiogram qualify as an "image" for purposes of this measure? We believe that the measure should explicitly focus only on radiology services and perhaps only on selected modalities," CHIME said.
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