In response to a Health and Human Services final rule issued late last month, HIMSS has voiced its opposition to the full-year meaningful use reporting requirement for 2015 using 2014 certified EHR technology.

The organization wrote a Sept. 10 letter to HHS Secretary Sylvia Burwell expressing its “deep concern” over the lack of flexibility that the rule provides for 2015, and called on HHS and the Centers for Medicare and Medicaid Services to revisit the requirement and allow providers, not in their first year, to achieve MU with 2014 CEHRT for any one three-month quarter in 2015 rather than a full year.

“HHS’s decision to require a full-year of reporting using 2014 Edition CEHRT in 2015 puts many eligible hospitals (EHs) at risk of not meeting MU for 2015,” states the letter. “Under current regulation, EHs must use 2014 CEHRT in less than one month. If they do not, they become ineligible for incentive payments andthey are subject to downward 2017 Medicare payment adjustments.”

While HIMSS acknowledges that Stage 2 outcomes and the 2014 Edition CEHRT are “important drivers toward successfully achieving positive transformation of the U.S. healthcare system,” the organization makes the case that the full-year of reporting in 2015 is not a realistic option for providers, who need additional time to fully implement MU Stage 2 as well as 2014 Edition CEHRT.

“Many providers who were trying to meet the previous deadlines for 2014 (and as applicable, MU Stage 2 in 2014) suspended those efforts and reconfigured their systems to meet the just-finalized 2014 requirements,” states the letter. “With the August 29 final rule, and 2015 requirements beginning for EHs on October 1, too many technology and process changes are required in too-short a period. In addition, the January 1, 2015, deadline for eligible professionals (EPs) to implement 2014 is nearly upon us. Requiring a full-year of reporting is unrealistic.”

HIMSS adds that “if a full-year of reporting is required for 2015, we fear that large segments of the provider community will no longer participate in the MU program.” The organization points out that a recent report from CMS on MU attestations through August 2014 suggests the full-year of reporting in 2015 is not a realistic option for providers.  As of Aug. 25, 143 EHs and 3,152 EPs have attested to Stage 2, according to CMS.

“The handful of providers already attesting to Stage 2 in 2014 may very well be well-positioned to meet the full-year reporting requirements in 2015. However, HIMSS believes it is very likely, given CMS’s data, that many EHs are not going to be able to comply with the 2015 MU reporting requirements beginning on October 1, and many EPs are not going to be ready by January 1.”

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