The College of Healthcare Information Management Executives (CHIME) has a handful of recommendations for the two federal agencies within the Department of Health & Human Services (HHS) responsible for the proposed changes to meaningful use in 2014.
In late May, the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) notified eligible providers in the EHR Incentive Programs that modifications to meaningful use 2014 were on the way with the purpose of providing greater flexibility to participating hospitals and physicians.
At the time, the leaders of CHIME made clear its concerns about the timing of the propose rule modifying meaningful use in 2014 — that is, if eligible hospitals (EHs) would be able to benefit from the rule. The association has now reiterated those concerns, urging CMS and ONC to move swiftly in finalizing the rule along with incorporating certain changes.
First, CHIME is recommending that CMS explicitly state whether eligible providers will be covered retroactively in 2014 and especially significant concern for EPs and critical access hospitals (CAHs) for which July 1 represents the start of the last available reporting period in 2014, a date that will come well before the proposed rule is finalized. Additionally, providers should have the option to report clinical quality measures of their choosing no matter the stage of meaningful use they are in.
Second, the association wants to see the 3-month quarterly periods be used as part of meaningful use in reporting year 2015. “Most providers who take advantage of the flexibilities proposed in this NPRM will need to report on Stage 2 measures and objectives in 2015, and most of these providers will not be in a position to report a full year of data, beginning October 1, 2014,” CHIME states.
Third, CHIME is seeking clarification around the implementation of 2014 Edition certified EHR technology (CEHRT):
There is widespread concern among CIOs that program auditors will be overly zealous in determining what implementation and workflow changes merit the ability to take advantage of the new flexibility. We appreciate the examples listed in this proposed rule and would urge CMS to give EHs and CAHs additional confidence by expanding those examples to include scenarios “outside the provider’s control” such as an underdeveloped ecosystem of exchange participants to receive summaries of care for transitions of care.
Lastly, CHIME is throwing its support behind the proposed one-year extension of Stage 2 Meaningful Use for providers who demonstrated meaningful use successfully in 2011 and 2012.
The comment period for the proposed rule closes on July 21, 2014 at 11:59PM ET. So far more than 400 comments have been received.