The American Hospital Association wants proposed rule making changes to the electronic health records meaningful use program to be quickly finalized.
The proposed rule brings new flexibility to meeting requirements of Stages 1 and 2 in 2014, but the rule also comes late in the game with Stage 2 already underway since last October for hospitals and since January for eligible professionals. The final 90-day reporting period for hospitals in 2014 starts on July 1 and many are not ready--they needed the flexibility of the proposed rule long before it came.
Due to the late timing of the proposed rule, we urge the agencies to finalize a rule that is at least as flexible as the proposal, the AHA pleads in a letter sent to the Centers for Medicare and Medicaid Services and the Office of the National Coordinator for HIT. The last-minute nature of the proposals pose significant risk and operational challenges to hospital leaders, who must make significant and consequential decisions about what actions to take to meet meaningful use during the last possible reporting period for FY 2014 without the certainty afforded by a final rule. 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, the argument continues. Therefore, a final rule that narrows the proposed flexibility could unfairly cause significant financial and operational harm to hospitals.
Done poorly, a final rule could push more providers out of the meaningful use program, the association warns. That said, the letter also includes a wish list of changes AHA would like before the rule is quickly finalized. The association wants more flexibility on the electronic clinical quality measures that hospitals must report in 2014, and clarification on documenting a hospitals justification for selecting one of four ways to attest for meaningful use under the proposed rule. Hospitals want to know if their choice could be subject to a future audit and financial penalty.
The association also asks that 2015 be considered a transition year as that is when many providers will first start Stage 2, so 2015 should have a 90-day reporting period instead of a full year. As acknowledged in the proposed rule, a central reason for the challenges being faced today is the requirement for a nationwide, simultaneous upgrade to a new certification level for EHR technology, according to the AHA letter. The flexibility in 2014 is helpful, but in reality provides only three months of additional time for providers to get up and running with Stage 2 requirements using the 2014 Edition technology.
Most hospitals just received or soon will get their updated EHR software for Stage 2 and will need until summer 2015 to complete their transition on a fast track, the AHA contends. Attestation from the time software is delivered is a 19-month process, according to the organization. That includes software assessment (three months); installation, implementation and training (eight months); building up to the most stringent performance metrics (five months); and meeting metrics for the reporting period (three months).
Finally, AHA asks the government to soften information exchange criteria in Stage 2 to meet current exchange infrastructure capabilities, and delay finalizing the start date of Stage 3, which is supposed to begin in October 2016 for hospitals. The associations letter is here.
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