The Healthcare Information and Management Systems Society and the American Medical Informatics Association are weighing with support for federal efforts to change and simplify the process of meeting requirements of the Electronic Health Record Incentive Program.
Among the most urgent suggestions is that of HIMSS, requesting that the Centers for Medicare and Medicaid Services move quickly to implement provisions to shorten the period for which hospitals and eligible professionals must report data to demonstrate that they’ve qualified to receive incentive payments.
Original rules for 2016 required hospitals and eligible professionals to gather data for all of 2016 to report performance. In July, CMS revised the rule to shorten that reporting period to 90 days.
That’s met with universal support from the industry, but Chicago-based HIMSS sent a letter late last week asking CMS to move promptly to formalize the 90-day reporting period before October 1, so that providers would be able to use the final quarter of the year to gather the data needed to substantiate their performance.
The association for healthcare information technology professionals is trying to avoid a repeat of last year, when CMS did not finalize a shorter reporting period until after October 1, which caused unnecessary bureaucratic work for providers.
“Although a 90-day reporting period was granted for Meaningful Use program participants in 2015, the policy was not finalized until after the start of the final reporting period, so many providers were not able to take advantage of the additional flexibilities,” said HIMSS in a letter to Andy Slavitt, acting administrator of CMS. “Instead, many providers relied on hardship exceptions under the expanded authority established under the Patient Access and Medicare Protection Act.
“In order to avoid a repeat in 2016, it is vital that the 90-day reporting period for 2016 be finalized as soon as possible,” the letter continues. “HIMSS wants as many providers as possible to remain part of the EHR Incentive Program, so finalizing the 90-day reporting period as quickly as possible will reduce the number of providers who must rely on hardship exceptions in 2016.”
HIMSS also asks for CMS to issue hardship exemptions if the final rule is not issued before October 1. That likely will be a challenge, as comments for the notice of proposed rulemaking can be submitted until September 14. In addition, proposed changes to the EHR incentive program are included in a proposed rule that encompasses several wide-ranging topics, including outpatient prospective payment programs, organ procurement, transplant outcome reporting and value-based purchasing program payments.
HIMSS' letter asks CMS to plan ahead for contingencies. “If the promulgation of this Final Rule is similarly delayed, CMS must be prepared to provide the flexibility for hardship exceptions as was done in 2015,” it urges.
Both HIMSS and AMIA support efforts in the rule to reduce administrative burdens, and their comments ask for CMS to redesign reporting requirements to eliminate differences between those required by Medicare and Medicaid.
“While we are supportive of the NPRM’s concerns that states would incur additional cost and time burdens in having to update their technology and reporting systems within a short period of time to make any changes in 2016, we are also concerned about the creation of two different sets of Meaningful Use criteria for Medicare and Medicaid,” HIMSS’ letter notes. “However, at this point in the program, provider flexibility in meeting Meaningful Use requirements outweighs any concerns about two sets of requirements” for eligible hospitals and critical access hospitals.
In addition, HIMSS recommends that CMS further align the reporting requirements for the Medicare and Medicaid EHR Incentive Programs with the Merit-Based Incentive Payment System (MIPS) “in order to limit the need for multiple reports from EHR technology products. Such a change will assist the program simplification CMS is seeking to achieve.”
“AMIA generally supports reducing reporting burden and therefore supports eliminating the clinical decision support and computerized provider order entry objectives and measures as CMS considers these objectives and measures to be ‘topped out.’ We also support CMS’ effort to ensure that the hospital reporting requirements are as consistent as possible with the EP requirements, which will minimize burden and confusion among both vendors and clinicians,” AMIA says.
In response to CMS’ request for comment on how future years of the program should evolve for hospitals. AMIA recommended that CMS augment future measures of meaningful use “based on proven functionalities, supported with clear evidence that such functionalities will improve care to patients.
“Future years of the program should seek to propagate new uses of health IT based on implementation experience across various settings, geographies and patient populations—not reflexively seek to usher unproven or unpiloted functionalities nationwide,” AMIA’s comments continue. “Further, we encourage CMS to seek measures that benefit population health and research without encumbering individual patients or their clinicians.”
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