The American Hospital Association (AHA) is asking the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) to move quickly in finalizing the proposed modifications to the EHR Incentive Programs in 2014.
In a letter to CMS Administrator Marilyn Tavenner and National Coordinator Karen DeSalvo, MD, MPH, MSc, the AHA is stressing the importance finalizing the proposed rule published last month in order for eligible providers to take advantage of its provisions.
“The proposed flexibility is much needed and would offer more choice in the specific meaningful use requirements they must meet in 2014 (Stage 1 or Stage 2),” writes AHA Senior Vice President Linda Fishman. “However, we are concerned that the extremely late release of the proposed rule will limit its benefit to hospitals.”
To rehash, the propose rule is intended to reduce burdens on eligible professionals (EPs) and hospitals (EHs) associated with EHR certification. Under the proposal, eligible providers would have the option of using certified EHR technology based on the 2011 or 2014 Edition criteria in the 2014 reporting year. However, all providers would be responsible for implementing and using 2014 Edition CEHRT in 2015.
Credit: CMS
While the proposed rule gives eligible providers greater flexibility in 2014, it has not removed the timing constraints on EHs which report according to the fiscal year and have until July 1, 2014, to take part in the last possible reporting period for the fiscal year ending in September.
“The last-minute nature of the proposals poses significant risk and operational challenges to hospital leaders,” Fishman explains. “Indeed, the comment period for the rule does not close until after the final reporting period has begun. Thus, hospitals are essentially asked to act on faith that the agencies will finalize these proposals as written — while risking that they may not — without the benefit of a later reporting period to conform to more stringent final rules.”
Beyond the call to finalize the propose rule quickly, the AHA continues to recommend that CMS and ONC consider additional changes to the EHR Incentive Programs:
• Provide greater flexibility in the electronic clinical quality measures reported;• Clarify and simplify how the rule would be implemented;• Recognize that 2015 also will be a transition year;• Learn from Stage 2 before finalizing the start date for Stage 3; and• Verify that the specific proposed changes to regulatory text support the intended flexibility.
The AHA’s concerns echo those of other provider associations, such as the College of Healthcare Information Management Executives (CHIME). The organization’s President and CEO Russell P. Branzell, FCHIME, CHCIO, commented on the importance of timing in his remarks last month. “If the government acts quickly to finalize the proposed rule, it will provide the flexibility needed for our members and their organizations to adequately optimize newly deployed technology and ensure success of the program,” he observed.
Proponents for delays of Stage 2 Meaningful Use have cited the lack of available CEHRT as a major focal point of their arguments and reason enough for the Department of Health & Human Services (HHS) to make changes to meaningful use in 2014. Although HHS, CMS, and ONC appear to be doing so now, their timing has many skeptical of whether it will make a difference.
Read the full AHA letter here.
