In the letter, the American Hospital Association, American Medical Association, Association of Medical Directors of Information Systems, College of Health Information Management Executives, Electronic Health Record Association, Federation of American Hospitals, and Healthcare Information and Management Systems Society make five main suggestions:
-- Reduce regulatory complexity.
-- Clarify certification and site certification processes.
-- Address providers' Meaningful Use resource requirements.
-- Clarify and improve registration, attestation, and compliance processes.
-- Evaluate regulatory timeline.
"We sometimes take for granted that everyone will understand the regulatory process," said Tom Leary, HIMSS senior director for federal affairs, "but when you talk to physicians from small offices, they say, 'I've got the regulations, but now these frequently asked questions have come out--do they supersede the regulations? How do I marry these up?' These providers have skill sets focused around patient care and need some help navigating this process."
The letter states: "Given the transformative nature of the incentive programs and associated funding and legal obligations, the healthcare community needs authoritative, timely, unambiguous, clear information, and resources that address the policy and operational implications for EPs and EHs."
The organizations suggest the following improvements:
-- Launch a unified HHS website that serves as the "single source of truth" for CMS's Meaningful Use and ONC's certification programs.
-- Launch "Meaningful Use and Health IT" checklist of tools detailing what each eligible provider (EP) or eligible hospital (EH) needs to address, as well as linking to resources from the Health Information Technology Resource Center (HITRC), which should be publicly available to all.
-- Increase HHS efforts to provide a technical assistance resource for hospitals, similar to the Regional Extension Centers (RECs), focused on rural hospitals and those providing care to patients in underserved areas.
-- Extend REC services to specialist categories, and evaluate the effectiveness of the RECs' physician outreach and assistance efforts.
-- Establish a clear process to manage updates to specifications for quality measures, making sure that all published updates to quality measure specifications include release notes so users can easily identify what has been updated in the quality measure specifications. They ask that CMS provide clear guidance as to whether the implementation of the updated measure specifications is a requirement to meet incentives qualification, or is an optional update to qualify for incentive payments. They also urge HHS to include a process by which providers and vendors can access guidance on specific measures and their specifications as well as to provide feedback on problematic or unclear measures.
The groups also state the Meaningful Use requirements themselves might be more appropriate if representation on the Advisory Workgroups was adjusted.
"We believe the workgroups of the Health IT Policy Committee, in particular the Meaningful Use Workgroup, would be better served if there was greater representation by those who are developing and implementing systems and particularly those who understand the unique needs of small practices," they said. "Providers are a critical resource for providing input on how health IT can be used to improve practice workflow and enhance care processes and clinical decision-making."
Leary said while there are some on the committee voicing the concerns of small practices, more individuals representing the small-to-medium contingent are needed. "You need boots on the ground--not just to be brought in for testimony, but actually on the committee and workgroups where they can participate in the development of recommendations."
Though Leary said the coalition has yet to hear back from Sibelius regarding its request for a meeting, he'll be "working closely with ONC and CMS staff to see if a meeting with the Secretary, or at least the department, can happen in the next few weeks."
The Healthcare IT Leadership Forum is a day-long venue where senior IT leaders in healthcare come together to discuss how they're using technology to improve clinical care. It happens in New York City on July 12. Find out more.