The College of Healthcare Information Management Executives, representing 1,400 chief information officers and other IT executives, generally supports a proposed rule published in May enabling providers to use the 2011 Edition of certified EHR technology for calendar and fiscal year 2014.
CHIME notes in a letter to the Centers for Medicare and Medicaid Services and Office of the National Coordinator for Health IT that the proposed flexibility will bring much needed relief to hundreds of thousands of providers struggling to meet MU requirements in 2014, due to circumstances beyond their control.
While concerned with the late timing of the rule, the association argues that options for using EHRs that have been certified under the 2011 Edition for either Stage 1 or Stage 2 for the purposes of the 2014 reporting year provide needed flexibility for EHR optimization, encourage continued participation in the program, and help maintain the upward trajectory of EHR adoption in the U.S.
Under the proposed rule from CMS and ONC, all eligible providers would be required to report using 2014 Edition CEHRT beginning in 2015. However, in its letter CHIME strongly urges CMS to adopt the 2014 policy, allowing providers to choose any three-month quarter EHR reporting period for fiscal year and calendar year 2015. CHIME believes providers will benefit from the option of reporting during one quarter of 2015, rather than the full year, states the latter. Most providers who take advantage of the flexibilities proposed in this NPRM will need to report on Stage 2 measures and objectives in 2015, and most of these providers will not be in a position to report a full year of data, beginning October 1, 2014.
In the preamble of the proposed rule, CMS and ONC include two examples of how a delay in getting certified technology would inhibit a providers ability to meet MU requirements in 2014. Specifically, in order to take advantage of new flexibilities proposed for program year 2014, providers must attest that they are choosing an alternative MU path due to CEHRT availability. Nevertheless, CHIMEs letter recommends that CMS omit the fully implement attestation requirement and asks CMS to be expansive in considering scenarios that have created, led to, or resulted in a situation where a provider was unable to fully implement 2014 Edition CEHRT.
We recommend CMS to clarify that this requirement (1) will be a step in the familiar attestation process, and (2) no additional documentation will be required as part of this aspect of the attestation process, states the letter. There is widespread concern among CIOs that program auditors will be overly zealous in determining what implementation and workflow changes merit the ability to take advantage of new flexibility. We appreciate the examples listed in this proposed rule and would urge CMS to give EHs and CAHs additional confidence by expanding those examples to include scenarios outside the providers control such as an underdeveloped ecosystem of exchange participants to receive summaries of care for transitions of care.
The proposed rule also includes a provision that would formalize CMS and ONC's recommended timeline to extend Stage 2 through 2016 and the earliest a provider would participate in Stage 3 would be 2017. CHIME supports the proposed one-year extension of Stage 2 for providers that first became meaningful users in 2011 and 2012. We agree this is a necessary extension to give policymakers time to evaluate past experience and incorporate lessons learned into the third Stage of Meaningful Use, states the letter.
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