“The AHA is very concerned that the high bar for achieving ‘meaningful use’ and the limited transitions proposed in the NPRM will severely limit hospitals’ ability to access these much-needed resources,” the organization stated in its recently filed comment letter to CMS. “We fear that the ultimate impact of the program actually could be the opposite of the goal of an e-enabled health care system, as those who are furthest behind may well be discouraged by the steep adoption curve.”
With less than eight months left before the program begins, very few hospitals can meet the proposed “all-or-nothing” approach, AHA continued, even though they have adopted or are adopting EHR systems. In a January 2010 survey with nearly 800 hospital respondents, less than 1 percent indicated they could meet all 23 of CMS’ proposed requirements to be deemed a “meaningful user” of EHRs today, the organization noted. CMS’ rule needs to offer an “incremental and flexible” plan that will support hospitals and physicians in achieving the ambitious goal that the Congress envisions, it said.
Hospitals also will be hampered in their adoption efforts by inadequate infrastructure and market pressures, AHA wrote. “The health IT market already suffers from limited vendor capacity, insufficient numbers of trained IT workforce, and shortages of clinical staff trained in IT. These constraints will be even greater in the face of skyrocketing demand from hospitals and physicians seeking to both install new EHR systems and make significant changes to existing, installed EHR systems to meet the certification and meaningful use requirements,” the letter reads.
Key concerns and recommendations in the letter include the following issues:
- Definition of Meaningful Use: “The AHA is concerned that CMS’ all-or-nothing approach and the very short timeframes set in the proposed rule are unrealistic. We urge CMS to consider an alternate approach that advances widespread health IT adoption throughout hospitals and sets requirements that are achievable and practical. Our alternative definition of meaningful use includes”:
- Modifying the proposed meaningful use objectives and adding 12 additional objectives;
- Replacing CMS’ proposed adoption year concept with an approach that allows hospitals to satisfy the meaningful use definition if they meet 25 percent of the objectives in 2011 or 2012, and increasing the percentages in future years;
- Expanding required levels of use and data sharing requirements over time;
- Changing many of the measures of meaningful use to decrease the reporting burden;
- Allowing hospitals to meet the meaningful use objectives by grandfathering currently installed and functioning hospital EHR systems as certified; and
- Relying on existing quality reporting structures until EHR quality measures and products for quality reporting are ready for broad use.
- Definition of a Hospital-Based Eligible Professional: “The AHA is concerned about the broad definition of a hospital-based professional that, contrary to congressional intent, severely limits the number of professionals that can participate in the programs. We present an alternative that allows more physicians to qualify appropriately for EHR incentives.”
- Definition of a Hospital: “The AHA is concerned about how hospitals are identified for the EHR incentive programs. We ask that each hospital within a system that has a single CMS certification number be evaluated individually for meeting the meaningful use definition and be eligible individually for incentive payments.”
- Critical Access Hospitals (CAHs): “The AHA is concerned that CMS has proposed to exclude CAHs from the Medicaid EHR incentive program. We urge CMS to reverse this decision.”