HIMSS’ Electronic Health Record Association and the American Medical Association (AMA) were among the many organizations to submit comments on the proposed rules for Stage 2 of Meaningful Use, with the HIMSS EHR Association calling for fewer clinical quality measures and more time for EHR upgrades, and AMA looking for greater flexibility on timelines.
In the letter submitted to CMS, HIMSS’ EHR Association expressed concern that both EHR vendors and users will “be challenged by the large number of proposed clinical quality measures and the dearth of available data on their final specifications.” The group also pointed out that the specifications for clinical quality measures will not be available until the summer, which puts vendors and providers under added pressure. Therefore, “CMS should finalize far fewer measures for Stage 2 and be highly selective on the measures chosen according to the criteria that we outline,” they noted.
In its comments to ONC, the Association voiced its support for the proposed one-year extension of Stage 1, and asked that providers who are still in Stage 1 of Meaningful Use in 2014 be allowed to continue using Stage 1-certified EHR systems rather than quickly transitioning to Stage 2-certified systems. “As was generally agreed across the industry and by the Health IT Policy Committee, a full 18 months is needed between release of the final rules and when providers need to upgrade,” the letter stated.
The AMA, along with 98 state and specialty medical societies, expressed concern in its letter to CMS that “the cumbersome proposed criteria will make successful physician participation extremely difficult.” The organizations submitted the following recommendations:
- Evaluate Stage 1 to inform the final Stage 2 requirements;
- Create more flexibility in meeting measures including exclusion and relevancy factors;
- Delete the high thresholds for new measures and for measures that cannot be met due to the lack of available, affordable, well-tested tools or exchange capabilities;
- Incorporate more focus on measures within a physician’s control;
- Include any proposed new measures for Stage 2 in the menu set of options;
- Allow a significant good faith effort to meet measures in Stage 2 to count for incentives and for avoiding penalties;
- Eliminate back-dating the meaningful use penalty program and establish a number of exemption categories for hardship cases;
- Synchronize and improve the overlapping health IT and quality program requirements;
- Establish an appeals process under both the meaningful use and e-prescribing programs; and
- Reduce the burden and add flexibility in regard to clinical quality measure (CQM) reporting and requiring testing of electronic specifications prior to use of a CQM.
“Overall, the proposed Stage 2 requirements need to provide more flexibility to foster widespread EHR adoption,” said AMA Board Chair-elect Steven J. Stack, MD. “Physicians are at varying stages of implementing health IT into their practices and should get credit for making a good faith effort to meet the meaningful use requirements.”