In making proposed changes to Medicare and Medicaid incentive programs for electronic health records, federal rule makers clearly responded to industry concerns about challenges providers face in achieving objectives.
In explaining the rationale for the changes, the Centers for Medicare and Medicaid Services frequently cited interactions with industry groups and their messages to federal regulators about the lack of industry preparedness or the inability to get consumers to use information technology.
The goal for the proposed rule “is to propose changes to the objectives and measures of meaningful use that we expect would reduce administrative burden and enable hospitals and CAHs (critical access hospitals) to focus more on patient care,” CMS states in the rule.
However, the agency also said it retains the right to review industry progress and institute tougher measures at later dates. The agency is tasked with improving the use of EHRs and healthcare quality “by requiring more stringent measures of meaningful use,” the rule states. “We intend to adopt more stringent measures in future rulemaking and will continue to evalue the program requirements and seek input from eligible hospitals and CAHs on how the measures could be made more stringent in the future.”
Here are some of the major areas of change within the proposed rule, as well as the rationale CMS put forth for the changes.
Proposed revisions to the EHR reporting period in 2016 for eligible professionals, eligible hospitals and CAHs. The reduction would be to set a 90 continuous day reporting period during 2016, instead of a full year. Stakeholders have said more time is needed to accommodate some of the updates from the 2015 EHR Incentive program final rule.
Elimination of the clinical decision support and computerized provider order entry objective and measures for hospitals and critical access hospitals. While this would not apply to eligible hospitals and CAHs attesting under a state’s Medicaid EHR Incentive Program, CMS said it believes the rule has “topped out,” with most providers attesting to have CDS and CPOE capabilities in place.
“We believe that the high level of successful attestation indicates achievement of widespread adoption of this objective and measures among eligible hospitals and CAHs, and that the objective and measures are no longer useful in gauging performance,” CMS wrote, and removing it will reduce administrative burdens.
Reduction in threshold for the view, download, transmit measure for Stage 2 in 2017. The measure would be reduced from 5 percent of patients to “at least one patient.” The agency says, “We are proposing to reduce the threshold because we have heard from stakeholders, including hospitals and hospital associations, that they have faced significant challenges in implementing the objectives and measures that require patient action.”
Reduction in the threshold for patient electronic access to health information for Stage 3 in 2017 and 2018. CMS proposes reducing the threshold from more than 80 percent to more than 50 percent, which would be based on the use of application programming interfaces to reach the goal.
“We continue to hear from health IT vendors…indicating, in part, that application development is in a fledgling state, and thus it might be very difficult for hospitals to be ready to achieve the 80 percent threshold,” the agency stated. “Application development has not been entirely market tested and widely accepted amongst the entire industry.” And issues might arise around compatibility and varying API interface functionality “that could possibly hinder interoperability among certified EHR technology.”
Reduction in the threshold for patient-specific education for Stage 3 in 2017 and 2018. CMS proposes a reduction in the limit from more than 35 percent to more than 10 percent. Patients receive most of this information in print form when they are interacting with healthcare professionals at discharge, and the rule would disproportionately disrupt most providers’ workflows.
Reduction in the thresholds for coordinating care through patient engagement for Stage 3 in 2017 and 2018. Similar to the proposal for Stage 2, this would reduce the view, download, transmit measure from more than 5 percent to at least one patient.
In the use of secure messaging, CMS proposes reducing the threshold for eligible hospitals and CAHs from more than 25 percent to more than 5 percent, saying patients have shown reluctance to use secure messaging. “We would like to provide eligible hospitals and CAHs additional time to determine the best ways to relay the importance for patients to use secure messaging as a communication tool with their healthcare provider,” CMS noted.
Reduction in the threshold for health information exchange for Stage 3 in 2017 and 2018. For the patient care record exchange measure, the threshold would be reduced from more than 50 percent to more than 10 percent. The reduction is being proposed because feedback from hospitals and recent surveys show “there are still challenges to achieving wide scale interoperable health information exchange.” Most stakeholders say there’s still a lack of health IT adoption to support electronic exchange among trading partners.
Reduction in the threshold for requesting and accepting patient care record measure for Stage 3 in 2017 and 2018. The threshold would be reduced from more than 40 percent to more than 10 percent, due to “challenges in achieving wide scale interoperable health information exchange.”
Reduction in the threshold for clinical information reconciliation for Stage 3 in 2017 and 2018. This involves three clinical information sets, for medication, medication allergy and current problem list, and the threshold would be reduced from more than 80 percent to more than 50 percent, again as a result of problems related to the lack of interoperable health information exchange.
Reduction in the threshold for public health and clinical data registry reporting for Stage 3 in 2017 and 2018. CMS proposes reducing the reporting requirement from any combination of six measures to any combination of three measures. Hospitals have reported that it’s difficult to find registries that are able to accept data that enable them to successfully attest to the measure.
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