In scathing formal comments submitted to the Centers for Medicare and Medicaid Services, the College of Healthcare Information Management Executives called the proposed Stage 3 electronic health records meaningful use rule from CMS unworkable and too ambitious.
Were all requirements finalized as proposed, we doubt many providers could participate in 2018 successfully, argued CHIME in its comments. And with so few providers having demonstrated Stage 2 capabilities, we question the underlying feasibility of many requirements and question the logic of building on deficient measures.
CHIME is particularly concerned with patient action requirements related to care coordination and unrealistic thresholds for health information exchange requirements. In addition, the organization is troubled over the requirement that all providers must attest to meaningful use Stage 3 by 2018, regardless of prior participation and experience with the program.
Following an optional year in 2017, starting in 2018 all providers under the proposed rule would report on the same definition of meaningful use at the Stage 3 level regardless of their prior participation, moving all participants in the EHR Incentive Programs to a single MU stage in 2018.
While we acknowledge policymakers intention to make each Stage more difficult than the last, we are concerned with the strategy that envisions Stage 3 serving as both the apex of MU requirements and as a starting point for those providers with no experience at Stage 1 or Stage 2 of the EHR Incentive program, cautioned CHIME in its comments. We worry some of the objectives pose too great a stretch for seasoned meaningful users, let alone those who have never participated in the program.
Further, if CMS has its way in Stage 3 MU, application programming interfaces (APIs) would replace patient portals as the preferred method adopted by providers to enable patients to view, download and transmit their health information. A proposed Stage 3 objective is to have eligible professionals and hospitals provide access for patients to view online, download, and transmit their health information, or retrieve their health information through an API within 24 hours of its availability.
We question the value of setting thresholds for technology and process not yet invented, let alone widely deployed in healthcare, said CHIME Board Chair Charles E. Christian. From the heavy reliance on APIs to an assumption that patient-generated health data will flow in standardized ways, our industry has a long way to go if it is going to catch-up with this rule by 2018.
To help address these and other perceived shortfalls, CHIME urged CMS to make several changes to the proposed Stage 3 rule, including:
*A 90-day reporting period for the first year of Stage 3 compliance, at least for payment adjustment purposes;
*Modify requirements for and retain the 90-day reporting period for providers attesting to meaningful use requirements for the first time, whether in a Medicare or Medicaid context;
*Eliminate patient action thresholds for the care coordination objective;
*Reduce the number of required measures in some objectives, such as health information exchange and care coordination;
*Create hardship exceptions for providers switching vendors;
*Allow providers to take a 90-day reprieve during any program year for upgrades, planned downtown, bug fixes related to new technology or optimizing the use of new technology within new workflows; and
*Allow, in limited circumstances, paper-based means to achieve measure thresholds.
Public comments to the proposed Stage 3 rule are due to CMS by May 29.
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