The American Hospital Association (AHA) filed its public comments on the EHR Incentive Program on Dec. 11, highlighted by a five-point set of recommendations to rework the platform for establishing meaningful use (MU) of certified EHR technology.
The AHA, representing nearly 5,000 member hospitals, health systems and other healthcare organizations, called for the following in a letter to Andrew Slavitt, acting administrator of the Centers for Medicare and Medicaid Services:
1. Allow a reporting period of any 90 consecutive days in the first year of a new stage of meaningful use. The recommendation would go into effect for the first year of Stage 3 and any subsequent stages, and “whenever there are changes to the definition of certified EHR, including a new edition of technology or new functionality.”
2. Push back the proposed start date of Stage 3 to no sooner than 2019. The current rule specifies a voluntary start date of 2017, with mandatory participation in 2018. AHA suggests that providers not be required to begin Stage 3 until at least 75 percent of eligible hospitals (EHs), critical access hospitals (CAHs) and providers (EPs), respectively, have met Stage 2. AHA’s plan would set 2018 as the voluntary start date of Stage 3, and would not require participation until the following year, when the Merit-Based Incentive Payment System and Advanced Payment Models go into effect for Medicare payments.
3. Do away with the all-or-nothing approach to meaningful use. AHA proposes that EHs, CAHs and EPs should not have to meet all of a set of meaningful use objectives in order to qualify for incentive payments or avoid payment adjustments. Instead, AHA says hospitals and providers that attest to 70 percent of meaningful use requirements be designated as having met MU.
4. Extend the attestation deadline. AHA suggests that the current 60-day attestation timeframe following the end of a reporting period be doubled to 120 days. The change would go into effect in spring 2016. AHA says it is concerned that the 60-day period is “too short to accommodate simultaneous attestations by as many as 665,000 EHs, CAHs and EPs.”
5. Use the program’s track record to inform future definitions of MU. AHA points out that only 40 percent of EHs and about 10 percent of EPs attested to Stage 2 in 2014. Accordingly, AHA calls for allowance of more time for additional providers to attest to Stage 2. The group also wants an independent study of providers’ experience with Stage 2 to be used as a gauge in setting Stage 3 requirements.
Additionally, AHA’s comments set forth recommendations to give providers more flexibility in meeting MU requirements while pursuing better-coordinated, value-based care. Among this set of recommendations, AHA says Stage 3 requirements should emphasize the availability of EHR functionality, rather than the number of times functionality is used. The group also proposes a hardship exemption from MU penalties for any provider or hospital that changes EHR vendors during a reporting period.
Looking ahead, AHA also argues that providers should not be required to use a standard or functionality in certified EHRs “in advance of evidence that the standard or functionality is ready for nationwide use.”
