CHIME: MU Stage 3 Is “Unworkable”

In comments submitted to CMS, CHIME expressed concern that Meaningful Use stage 3 is “too ambitious” and called for several key changes, including a 90-day reporting period for the first year of compliance.

“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,” stated the organization, which cited “unrealistic” thresholds for health information exchange and patient engagement requirements in stage 3.

CHIME is asking for a number of revisions, including:

• Modify requirements for and retain the 90-day reporting period for providers attesting to MU 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 multi-measure objectives, 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.

“We question the value of setting thresholds for technology and process not yet invented, let alone widely deployed in healthcare,” said CHIME Board Chair Chuck Christian, Vice President of Technology and Engagement with the Indiana Health Information Exchange. “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.”

The organization also voiced support for a CMS proposal that would shorten MU reporting in 2015 from a full year to any continuous 90-day period.