The American Medical Informatics Association is generally pleased with electronic health records provisions that CMS proposed in April as part of a major rule covering hospital inpatient and long-term care hospital prospective payment systems for Fiscal Year 2018.

“Generally, AMIA is supportive of the proposed flexibilities afforded to providers for quality reporting and quality payment programs, for example the 90-day EHR Incentive Program reporting period, and reduction of required quality measures,” the trade association said in a comment letter to CMS.

With many providers needing to update to the 2015 edition of meaningful use EHRs, AMIA believes the providers will benefit from additional time to implement, test and adjust workflows.

Doug Fridsma, MD
Doug Fridsma, MD

“It is vital that the industry continue its march toward modernization,” Douglas Fridsma, president and CEO at AMIA said. “Application programming interfaces and other key aspects of the 2015 edition will help improve care through improved interoperability and better patient access to their data.”

AMIA supports a CMS proposal to reduce hospital reporting of electronic clinical quality measures from eight to six, and be able to submit two self-selected quarters of data, a significant reduction from the previous requirement of one full year of data. The group also likes having hospital reporting requirements aligned with eligible professional requirements for the Merit-based Incentive Payment System requirements, minimizing burden and confusion.

However, “We do urge that CMS allow use of any two quarters during 2018 (as is proposed for 2017) to allow hospitals to reuse data extraction processes in 2018 that were used in 2017 and provide more flexibility and time for hospitals to upgrade and fully implement 2015 CEHRT,” the association asked.

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While CMS proposes to maintain the requirement that EHRs be certified to the 2015 Edition of meaningful use for clinical quality measures reporting, the agency also proposes that such EHRs need not be recertified each time the EHR is updated to a more recent version of the quality measures. The certification and upgrades should enable eligible professionals and hospitals to successfully attest for an EHR reporting period in 2018, according to CMS, and AMIA agrees. “We anticipate that this approach will encourage continued and sustained resources on IT-enabled care delivery.”

CMS further proposes changing the reporting period for eligible professionals reporting clinical quality measures electronically in the Medicaid EHR Incentive program to a minimum of a continuous 90-day period during calendar year 2017. Eligible professionals choosing to attest rather than report electronically and have previously demonstrated meaningful use would report for the full year.

In its comments to CMS, AMIA also voices concern about ICD-10 coding update proposals, which could interfere with consistent clinical vocabulary maintenance. CMS is making some changes to how it describes certain codes. A core principle of clinical vocabulary maintenance, the trade group notes, is that the meaning of a code should not change over time.

AMIA’s complete seven-page letter to CMS is available here.

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