A proposed rule from the Centers for Medicare and Medicaid Services updating the Quality Payment Program includes several provisions that will affect healthcare providers continuing in the electronic health record meaningful use program.

The College of Healthcare Information Management Executives, a trade association serving chief information officers and other information technology professionals, likes much of what CMS is proposing in the rule, but an analysis by the organization identifies several provisions that prompt concern.

Physicians, for instance, may continue to use the 2014 Edition of meaningful use EHRs to attest to compliance in 2018. CMS had been planning to require use of the 2015 Edition of EHRs, and CHIME argued that neither physicians nor EHR vendors could be ready in time.

CMS listened, says Leslie Krigstein, vice president of congressional affairs at CHIME. The agency offered a “pick your pace” plan for 2017 under which physicians, using a 2014 Edition EHR, need only to attest to one quality measure to avoid a financial penalty in 2018 for failure to attest to meaningful use. Physicians also must achieve “three points” by making three attestations on EHRs—that they did not knowingly take action to limit or restrict the compatibility or interoperability of a certified HER; that the EHR was at all times in accordance with applicable law; and that the provider responded in good faith and a timely manner to requests to exchange electronic health information. In 2018, they must achieve a total of 15 points.

Leslie Krigstein
Leslie Krigstein

Or, physicians could use the 2015 Edition all year in 2017 and get a 10 percent bonus from Medicare.

That’s the good news. The bad news is that while hospitals are allowed a 90-day reporting period for 2018, they need to use the 2015 Edition, and most vendors’ products are not yet certified for the 2015 criteria. A recent informal survey of CHIME members found that 81 percent of IT leaders’ vendors have not yet received their 2015 Edition EHR certification, and 70 percent don’t expect their EHR to be ready on Jan. 1, 2018.

As of May 30, fewer than 15 products are listed as ONC-certified EHRs meeting 2015 certification standards for each of the six public health options, and at this time, only 13 products meet 2015 criteria for application programming interfaces, according to CHIME.

Krigstein contends it could take eight months before a hospital is safely ready to use the EHRs certified under 2015 criteria for reporting in 2018, and as long as 18 months for a delivery system to be ready. “That means there is no time to work on usability—they’re just rushing to meet implementation deadlines,” she adds.

“Looking back to July 2016, 4,250 of 4,474 hospitals participating in the EHR incentive program were using 2014 CEHRT (certified EHR),” Mari Savickis, vice president of federal affairs at CHIME, wrote in a column on June 22. “Ten EHR vendors supplied 2014 CEHRT to 98 percent of hospitals. Of these ten vendors, two make up just under 50 percent of all hospital-certified products.” The vendors, according to Krigstein, are Cerner and Meditech.

Since it's already June, only six months remain in Calendar Year 2017 for EHR products to be certified in time for 2018, and providers are not ready, vendors are not ready, and the rules are only just being proposed.

To make matters worse, physicians need to use the 2014 Edition EHR while hospitals need to use the 2015 EHR, which means providers won’t have integrated ambulatory/inpatient systems but will be working off two different systems. And that goes for hospitals’ affiliated physicians, as well, according to Krigstein. “This is a big challenge for CIOs who have to maintain this complexity.”

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