The College of Healthcare Information Management Executives, representing CIOs and other senior health IT leaders, is urging the Centers for Medicare and Medicaid Services to delay the start of Stage 3 Meaningful Use until at least 2019.
The delay would give providers and vendors the opportunity to adjust to recently announced changes to Stage 2 and to focus on solving interoperability challenges. Currently, the mandatory start of Stage 3 is 2018. However, in a Dec. 14 letter to CMS, CHIME noted the timeline is not seen as reasonable by CIOs and vendors for ensuring that certified electronic health record products are available in the marketplace, arguing that Stage 3 should begin no earlier than 2019—and only after 75 percent of all eligible providers have met Stage 2 requirements.
“Beginning Stage 3 in 2019 offers providers more time to focus on many of the beneficial changes CMS recently made under Stage 2,” states the letter. “Pushing the Stage 3 start time to no sooner than 2019 would give the industry more time to learn what worked well under Modified Stage 2 and properly re-orient Stage 3 to best position providers for success under new payment and delivery models of care.”
Besides delaying Stage 3, CHIME also made the following recommendations:
* Removing the 2017 transitional year for meeting Meaningful Use Stage 3 and require 2015 Edition Certified EHR Technology no earlier than 2018;
* Establishing a 90-day reporting period for every year of the program, including the first year at Stage 3, to allow providers adequate time for upgrades, planned downtime, fixes related to technology or optimizing the use of new technology within workflows;
* Creating parity for both eligible providers and eligible hospitals by removing the existing pass/fail approach for Meaningful Use, and;
* Reducing the burden for providers by streamlining reporting redundancies and refraining from requiring data collection and submission on measures that do not advance patient care.
“We are concerned that not only is 2018 an unrealistic timeframe for the vast majority of providers to meet Meaningful Use, but that 2017 also represents an unreasonable timeframe to require vendors to deliver 2015 Edition CEHRT to the marketplace,” states CHIME. “Under current rules, vendors will need adequate time to develop software that can be tested and safely deployed. To date, many vendors have been unable to deliver updated certified products to the market due to late and shifting federal policies. We worry about their ability to deliver 2015 Edition certified EHRs by 2017 given these previous challenges.”
CHIME’s letter was in response to a CMS request for comments from stakeholders regarding the final Stage 3 rule, with comment period, that was published by the agency in October.
“We do not believe that the course laid out by the Centers for Medicare and Medicaid Services for Stage 3 will help us achieve some important goals, including better alignment of quality improvement efforts and widespread health information exchange,” said Charles Christian, chair of the CHIME Board of Trustees, in a written statement. “We need to let providers and vendors continue down the adoption curve and perfect systems that many are still putting in place.”
Support continues to grow among industry groups for delaying the start of Stage 3, who also have been putting pressure on Congress to delay the final stage of Meaningful Use. Last month, an American Medical Association-led coalition of 111 medical societies sent a letter to congressional leaders requesting that lawmakers halt Stage 3 until Stage 2 can be significantly reformed. Also See: Medical Societies Again Plead Congress to Fix MU Stages 2 & 3
For its part, CHIME is trying to work with CMS to affect change in the final Stage 3 rule.
“CHIME appreciates the increased flexibility CMS created in Stage 2 and the agency’s willingness to receive comments on Stage 3 regulations,” said Christian. “We are all striving to create a more efficient delivery system; one that improves patient care and lowers costs. CHIME looks forward to working with its partners in the federal government and other stakeholders as we drive towards those goals.”
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