The American Hospital Association has come out against federal proposals to link requirements to promote interoperability to conditions of participation in the Medicare program for hospitals and critical access hospitals.
The AHA’s comments are included in its response to proposed rules from the Centers for Medicare and Medicaid Services on its plans for the inpatient prospective payment system for Fiscal Year 2019.
The CMS’s proposed rule sought comments on efforts to increase the interoperability of health information through the creation of conditions of participation for hospitals and critical access hospitals.
The nation’s largest hospital organization said it “strongly opposes” the creation of such conditions, saying it doesn’t believe that creating such conditions will be an effective mechanism “to advance health information exchange.” Even so, the organization says it “strongly supports the creation of an efficient and effective infrastructure for health information exchange.”
Despite provider efforts to pursue information exchange and the progress made in implementing electronic health records systems, other factors stand in the way of interoperability, according to AHA. “The commitment of healthcare providers is not sufficient by itself to create interoperability,” the organization’s comments note. “The technical and organizational infrastructure must be available and allow for efficient exchange, and all parties to exchange must be using compatible technology in consistent ways.
“We urge CMS to recognize the impediments to information sharing and address them directly,” the group says. “We do not believe that creating a (Condition of Participation) or (Conditions for Coverage) that would apply to only one set of actors is an appropriate strategy.”
Widely known barriers to information exchange should be addressed first for interoperability to really take hold. “The AHA urges CMS to focus its attention on resolving problems created by the lack of a fully implemented exchange framework, adoption of common standards and incentives for EHR and other IT vendors to adhere to standards.”
The AHA also says it is concerned about the costs of achieving the scope of interoperability needed to comply with such requirements, citing estimates from a recent survey on the regulatory costs associated with achieving health IT. On average, surveyed facilities “spend $760,000 annually meeting regulatory requirements, most of which is being used to hire and maintain additional staff. Hospitals made additional IT investments averaging $411,000 during the year for the Promoting Interoperability Program, an investment more than 2.9 times larger than that made in any other area.”
CMS can use other initiatives to hold hospitals accountable for supporting information exchange, particularly through the Promoting Interoperability Program. “The AHA supports the advancement of and adherence to a framework for interoperability so that the technology and the rules governing the exchange of health information are universally and consistently implemented,” its comments note.
In addition, the AHA opposes the use of Stage 3 requirements in the continuation of the EHR Meaningful Use Program, saying it believes “the level of difficulty associated with meeting all of the Stage 3 current measures is overly burdensome.”
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