CHIME led off its comments expressing dismay at the short comment period, based on early proposals from the HIT Policy Committee, which interfered with the holidays and end-of-year professional commitments of CIOs. “We also wish to acknowledge the difficulty of commenting on a number of the proposed objectives and measures for Stage 3 and related issues at a time when there is still limited information regarding Stage 1 and no real experience under Stage 2.”
As the American Medical Association and American Hospital Association also contended in their comment letters, CHIME would like to see an evaluation of where the meaningful use program is before Stage 3 proposals become real. “Suffice to say that it will be important to re-assess the reasonableness of proposed Stage 3 objectives and measures in light of actual experience under prior stages. We see no value in setting unrealistic performance thresholds or expectations before current evaluations of what we have accomplished have been undertaken.”
The association in its letter reminded Farzad Mostashari, M.D., national coordinator for HIT, that each new objective in future meaningful use stages brings new significant costs to comply even as incentive payments decline over time. “This dynamic makes participation in subsequent stages less and less palatable for providers, jeopardizing the fundamental aim of bringing the nation’s healthcare system into the 21st Century.”
CHIME further expressed concern about turmoil in the EHR vendor space from consolidations, business failures or decisions to not pursue meaningful use compliance that could force providers to change vendors between stages. The organization asked for some type of accommodation for providers that must transition EHRs at the same time they are expected to move from one stage to another. CHIME’s comment letter is available here.