HIMSS Response to MU Rule Mostly Positive

In a June 15 letter to the Centers for Medicare and Medicaid Services, the Healthcare Information and Management Systems Society voiced its strong support for a CMS proposed rule that would ease compliance with Stages 1 and 2 of the electronic health records meaningful use program.

Released in April for public comment, the proposed rule would change the Medicare and Medicaid EHR Incentive Program reporting period in 2015 to a 90-day period aligned with the calendar year, and also would align the EHR reporting period in 2016 with the calendar year. In addition, the rule seeks to modify measures in the Stage 2 objectives related to patient engagement, as well as streamline the program by removing reporting requirements on measures which have become “redundant, duplicative, or topped out through advancements in EHR function and provider performance for Stage 1 and Stage 2.”

Also See: CMS Seeks More Changes to MU Stages 1 and 2

In its letter to CMS, HIMSS said it strongly supports the proposal to change the 2015 MU reporting requirements to any continuous 90-day period within the calendar year, and is supportive of calendar year reporting for all providers beginning in 2016. However, HIMSS cautioned CMS to ensure that the final 2015 program requirements take into account the “timing of the publication of this Final Rule and the complexities for the short turnaround in meeting these requirements before the end of calendar year 2015.” 

HIMSS also proposed that CMS phase-in new thresholds for the Patient Electronic Access Objective measures that “account for the challenges facing some providers in meeting these requirements.” And, the organization urged CMS to “take the same phased-in approach toward secure electronic messaging objective measure thresholds.”

While the overall tone of the letter was positive, HIMSS raised a number of concerns with the CMS proposed rule including requirements around measures associated with transmission to/from immunization registries, and to public health agencies, in the 2015-2017 timeframe. In particular, the organization questioned whether public health agencies are ready to accept much of the data related to syndromic surveillance and case reporting.

“Although CMS includes several exclusions for 2015 in the public health section of this proposed rule, HIMSS suggests that CMS reconsider these public health related reporting requirements until the field is fully prepared, the standards have been thoroughly tested, and have gained further adoption among stakeholders,” states the letter.

HIMSS also recommended that CMS re-evaluate the 2016 hospital e-prescribing requirement. While the organization supports the “adoption and use of e-prescribing to enhance patient safety,” HIMSS argued that the “proposed requirement for all hospitals to be compliant with e-prescribing by 2016 of 10 percent is an unrealistic goal,” according to the letter.

“Given that discharge e-prescribing was previously a Stage 2 menu objective, many eligible hospitals have decided to deploy e-prescribing in Stage 3. As a result, e-prescribing is neither in their current workflows nor do these providers have current experience with e-prescribing functionality,” concludes HIMSS.