CMS Told to Fix Stage 2 MU before Moving to Stage 3

The American Medical Association has joined a growing chorus of stakeholder groups calling on the Centers for Medicare and Medicaid Services to fix the Stage 2 electronic health records meaningful use program before advancing to Stage 3.


The American Medical Association has joined a growing chorus of stakeholder groups calling on the Centers for Medicare and Medicaid Services to fix the Stage 2 electronic health records meaningful use program before advancing to Stage 3.

“As we’ve said many times, the meaningful use program is not meaningful in its current form and is not helping physicians use electronic health records in a way that facilitates the best care coordination, increases efficiency or improves the quality of care for patients,” said AMA President-elect Steven J. Stack, M.D. “We cannot ignore the current problems and barriers that exist with the program.”

Case in point: AMA argues that less than 10 percent of eligible professionals were able to attest for Stage 2 Meaningful Use in 2014. According to the nation’s largest physician group, many health IT systems obstruct interoperability through excessive vendor fees or technical limitations that hinder physicians’ ability to meet Stage 2 and “without focusing on the cornerstone issues integral to interoperability and quality improvement, the meaningful use program will never be truly meaningful.”

Similarly, a coalition of organizations representing hospitals and health systems—including  America’s Essential Hospitals, American Hospital Association, Catholic Health Association of the United States, Children’s Hospital Association, and Premier healthcare alliance—has urged CMS to refrain from finalizing the proposed Stage 3 rule at this time and to focus instead on Stage 2 MU while accelerating the availability of mature standards and the infrastructure needed for health information exchange.

Also See: Stage 3 Proposals are Not Yet Feasible, AHA Says

In a letter to Health and Human Services Secretary Sylvia Burwell, the groups expressed their concern about the overall readiness of existing health IT infrastructure to support the successful attainment of proposed Stage 3 requirements in 2018.

“We believe that providing additional time for maturation of implemented technology and optimization to support meaningful use and other regulatory requirements is the right policy to keep all stakeholders focused on the activities that will support the better quality care for patients and for populations,” they told Burwell. “We believe the creation of an efficient and effective infrastructure for health information exchange is essential to support the delivery of high-quality, patient-centered care and is a precursor to many of the proposed advances for Stage 3.”

However, the Healthcare Information and Management Systems Society is more sanguine in its approach. In comments to CMS on the proposed Stage 3 rule, HIMSS reaffirmed its commitment to making the EHR Incentive Program “less prescriptive and more focused on encouraging and assisting providers to take advantage of the substantial capabilities established in meaningful use Stages 1 and 2.” 

In addition, HIMSS said it was encouraged by proposals to simplify and reduce the complexity of the meaningful use program. Specifically, the group applauded the CMS proposal in Stage 3 for a single definition of meaningful use starting in calendar year 2018—no matter when a provider began to participate in the EHR Incentive Program—asserting that this simplification will be for the benefit of both EHR users and developers.  

At the same time, the group voiced its concern about the timeline for transitioning to Stage 3 in 2017 and 2018. “Since the beginning of the Meaningful Use program, HIMSS has reiterated its position that 18-months is the minimum length of time needed between the final rules on meaningful use, certification, and standards, and the start of any stage of meaningful use,” according to the letter to CMS. “Given the likely timing for a release of the final Stage 3 rules, this will certainly not allow for a full 18-month timeline before the beginning of the 2017 optional year and realistically timing will be tight for 2018 with a full year of reporting, especially given the scope and complexity of the ONC 2015 Edition proposed rule.”

Consequently, HIMSS recommended to CMS a 90-day first reporting period in 2018 for Stage 3 rather than the proposed entire calendar year to “allow for a ramping up period so that providers can acclimate to this new stage.

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