The AHA Dec. 11 urged the Centers for Medicare & Medicaid Services (CMS) to revise the Electronic Health Record (EHR) Incentive Program framework to reflect experience and the need for flexibility, and delay new requirements until the health information exchange standards and infrastructure are “mature” enough for nationwide use.

To reach its goal of EHR adoption and use across a sizeable majority of eligible hospitals (EH), critical access hospitals (CAH) and eligible professionals (EP), CMS needs to reorient the program’s framework and timeframe to provide “operational and strategic flexibility for participating providers to enable them to achieve our shared national vision of an e-enabled health care system,” wrote AHA Executive Vice President Tom Nickels in comments on the Oct. 6 final rule for the EHR programs.

In releasing the final rule, CMS announced a 60-day public comment period to gather additional feedback about the incentive programs going forward.  The meaningful use incentive program, created under the 2009 HITECH Act, provides physicians and hospitals incentive payments under Medicare and Medicaid to implement EHRs, but also reduces payments for those that do not.

The final rule moves from fiscal year to calendar year reporting for all providers beginning in 2015, and offers a 90-day reporting period in 2015 for all providers, for new participants in 2016 and 2017, and for any provider moving to Stage 3 in 2017.

The AHA’s letter includes specific recommendations to improve the structure of the program, increase flexibility and base meaningful use requirements on what the association describes as “mature” standards.

In its call for structural improvements, the AHA recommended the final rule allow a reporting period of any 90 consecutive days in the first year of a new stage of meaningful use, and postpone the required start of Stage 3 until at least 2019. And the association said that an EH, EP or CAH that attests to meeting 70% of EHR requirements should be designated a meaningful user.

On flexibility, the AHA recommended measures that, among things, would focus more on the availability of “mature functionality in certified EHRs, rather than count the use of functionality;” provide a hardship exemption from penalties for any EH, EP and CAH that changes vendors during a reporting period; and uniformly apply to all providers any modification to program requirements.

The transition to new technology has been a challenge for providers due a lack of “vendor readiness, mandates to use untested standards, insufficient infrastructure to meet requirements to share information and compressed timelines,” the AHA stated. CMS should not require providers to use a “standard of functionality in certified EHRs in advance of evidence that the standard or functionality is ready for nationwide use. Robust testing and implementation guidance of mature standards must precede requirements for provider use.”     


2015 Edition health IT certification.In other health IT news, the Office of the National Coordinator for Health Information Technology Dec. 11 published a notice correcting technical errors in its Oct. 16 final rule for the 2015 Edition HIT certification criteria.

The notice also clarifies requirements for the exchange of the Common Clinical Data Set in support of transitions of care, the approach to privacy and security certification, and mandatory disclosures by health IT developers during certification and random surveillance. Like the final rule, the corrections and clarifications take effect Jan. 14.


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