The organization representing electronic health records vendors is urging federal agencies to provide clearer, more specific determinations on final rules as early as possible to aid in the implementation of new system capabilities by healthcare organizations.
In a letter to the Center for Medicare and Medicaid Services, the Electronic Health Record Association (EHRA) says it’s crucial for clear rules to be provided quickly to the industry, and for more engagement of providers in the design of the program.
The EHRA’s comments were included in a letter submitted last week with its comments on CMS’ proposed rule on the Quality Payment Program for 2018, which was published in late June.
EHRA’s letter says it understands the desire of regulators to add flexibility to the program to enable providers to meet program goals, but it urges them to realize the impact that short timelines have on EHR vendors and on providers’ ability to implement the revised systems.
“While recognizing CMS’ desire to add such flexibility, we do have concerns that repeated delays in program implementation timelines, as we have seen over several regulatory cycles, as well as a continued lack of clarity around requirements, may discourage clinicians from adequately preparing for MIPS’ future performance periods.”
MIPS, the Merit-based Incentive Payment System, is a new program being implemented by CMS to change the way that providers are reimbursed for treating Medicare patients, moving payment to a value-based approach that emphasizes improvements in quality. The new system will require many changes in the systems used by providers, which must be programmed into existing EHR products.
The EHRA is raising concerns because past regulatory efforts affecting clinical systems have been made more difficult by late releases and lack of specificity, putting pressure on providers as they implement new systems.
“Repeated delays and changes to prior levels of expected compliance can condition providers to delay implementing necessary and beneficial changes in technology and its use in clinical practice,” the EHRA letter says.
Improvements in implementation are crucial in helping providers realize benefits from the systems, EHRA says. “Many provider organizations and developers have invested in significant technical upgrades and process improvements. Being unable to realize a return on those investments because deadlines are moved create disincentives to aggressive participation in future years.”
EHRA, which represents 30 companies that develop records systems, believes it’s most important for federal agencies to provide clearer guidance to the industry on regulations to enable faster adaptation to the requirements, says Sasha TerMaat, chair of the organization’s executive committee and a director at Epic.
“Clarity is the most important issue to us,” she says. “Any program with 491 pages in the Federal Register is clearly very complex. To make the program successful, providers and EHR developers will need clarity from CMS to understand new concepts like virtual groups, subgroups, rewritten cost scoring measures and new approaches to measuring improvement.”
Those new concepts in the proposed federal regulation have been anticipated in the restructured reimbursement program, but specific details about how they will be implemented have not yet been released in final form.
Delays in regulations have significant downstream effects on both EHR vendors and providers, TerMaat notes.
“EHR developers plan their development based on input from their users and their users’ needs for tools that help them with regulatory programs like the QPP,” she notes. “To be able to deliver tools that meet healthcare organization’s needs, developers have to work ahead.
“When programs frequently introduce changes, it is more difficult to be able to plan what development will be the most useful and to schedule that development for the best time,” she adds. “There starts to be a general expectation of continued delays across the industry, and that erodes energy and momentum toward goals such as advances in interoperability.”
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