In comments submitted late last week, CHIME offered general support for the Meaningful Use incentive programs, but is asking for additional flexibility with the proposed changes, which were released in late May.
CHIME is asking that CMS allow providers to choose any three-month quarter for an EHR reporting period in the next federal fiscal year or calendar year to qualify for Meaningful Use in 2015. As currently structured, the program requires providers to report a full year of data to qualify for incentives.
“We believe this change will have a dramatically positive effect on program participation and policy outcomes sought in 2015,” the letter stated. “The additional time afforded by this modification would help hundreds of thousands of providers meet Stage 2 requirements in an effective and safe manner.”
Russell Branzell, president and CEO of CHIME, stated that although the pathways created by this NPRM will enable hospitals and physicians to capitalize on progress they’ve made, “the benefits of this new flexibility will be immediately lost if 2015 reporting requirements are not tempered. Carrying forward the 2014 policy requiring providers submit data covering one quarter of their choosing in 2015 is common sense.”
CHIME’s comments also requested that the agencies delete ambiguous attestation requirements related to the definition of “fully implemented” Certified EHR Technology (CEHRT). “A number of CHIME members have indicated their apprehension to take advantage of the new pathways created by this NPRM (because of) how this proposed rule defines ‘full implementation’ of CEHRT since the examples do not adequately represent their situation,” the comments stated.
“Given the industry’s experience with Meaningful Use audits, there is a lot of anxiety over how such a requirement would be validated,” said CHIME Board Chair Randy McCleese, VP and CIO at St. Claire Regional Medical Center. “The fear generated by meaningless audits can be crippling for small and rural organizations like ours. Ambiguity in what constitutes ‘full CEHRT implementation’ defeats the primary intent of this NPRM – namely, to encourage continued participation in the program.”
CHIME is asking agencies to “explicitly state its intentions to let providers meet MU requirements retrospectively in 2014, if they are able.” The organization also offered its support of the one-year extension of Stage 2 for providers that first qualified as meaningful users of EHR technology in 2011 and 2012. “This is a necessary extension to give policymakers time to evaluate past experience and incorporate lessons learned into the third Stage of Meaningful Use,” CHIME noted.