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The Healthcare Information and Management Systems Society joined provider groups and hospital associations May 7 in urging the Centers for Medicare & Medicaid Services to revise and extend the timeline for its electronic health record incentive programs.
HIMSS “strongly suggested” that CMS incorporate a 90- to 180-day reporting period for the first year of Stage 2 for the Medicare and Medicaid EHR incentive programs in 2014, and also encouraged the agency to continue reviewing and assessing the programs' timeline to give eligible professionals, eligible hospitals, and vendors adequate time to prepare for Stage 2.
The HIMSS comments reflect similar recommendations to CMS from the American Hospital Association, the Federation of American Hospitals, the College of Healthcare Information Management Executives, the American Medical Association, and the Medical Group Management Association (see previous article).
However, the Health IT Now Coalition, urged CMS to not delay the incentive program timelines, and to further strengthen the proposed Stage 2 meaningful use criteria for health information exchange.
According to the Coalition's comments, CMS' proposal to delay implementation of Stage 2 for providers and hospitals who attested to meaningful use of EHRs in 2011 “could squander an important opportunity to improve interoperability in 2013, when Stage 2 would have originally started.”
CMS released the proposed Stage 2 meaningful use criteria Feb. 23, and they were published in the March 7 Federal Register (77 Fed. Reg. 13,698, March 7, 2012)(see previous article). Public comments were due May 7.
HIMSS expressed support for the proposed Stage 2 meaningful use criteria to align clinical quality measure reporting and to encourage the use of mobile devices in health care.
“We appreciate the incredible commitment the [Department of Health and Human Services] has placed on engaging in a public dialogue and agree that the [meaningful use] program encourages standards-based collection, analysis, and exchange of health data in a safe and secure environment that can help providers, hospitals, and consumers improve care delivery for all Americans,” HIMSS Executive Vice President Carla Smith said in a statement.
HIMSS comments to CMS also included recommendations:
• that clinical quality measures be required only if the standard and specifications supporting the quality measures have been tested and verified;
• to support the new “base“ EHR definition for EHR certification; and
• to address future criteria in the proposed rule related to accounting of disclosures and data portability.
The Health IT Now Coalition urged CMS to raise the bar for health information exchange criteria and widespread interoperability among EHR systems.
Specifically, CMS should raise the bar for Stage 2 criteria by:
• preventing vendors and health care organizations from blocking health information exchange among providers;
• adopting more robust interoperability standards;
• promoting greater patient engagement; and
• coordinating quality measures among Medicare and Medicaid programs.
The Health IT Now Coalition recommended that all providers move toward adopting longitudinal EHRs for patients that could be shared by a network of providers and used for querying health data. “This is a critical component of the effort to lower costs and promote better patient care,” the Coalition said.
CMS should require providers to exchange summary of care documents using an EHR, including exchange with pharmacists, laboratories, pathologists, mental health providers, and payers, according to the Coalition's comments.
The Health IT Coalition and HIMSS both supported proposed criteria that would promote patient engagement and care coordination.
Proposed Stage 2 criteria would require providers to allow patient access to their data via a patient portal, or through download, view, and transmit EHR capabilities.
HIMSS stated support for ensuring the availability of electronic access for patients and their authorized representatives and care givers. However, it recommended that CMS consider including flexibility in the requirements for eligible professionals who deliver care to a predominantly visually or mentally disabled population, such as geriatric specialists and retinal specialists, or providers who treat English-deficient populations.
The Health IT Now Coalition recommended that CMS include patient education and outreach in the patient access criteria, since “portals will not be useful if patients do not know how to use them.”
Consumer advocacy groups recently voiced support for inclusion of patient engagement objectives in the proposed Stage 2 meaningful use criteria in response to comments from the American Hospital Association to CMS that the objectives were not feasible (see previous article).
The Electronic Health Record Association, a HIMSS trade association comprised of EHR vendors, applauded CMS for proposed Stage 2 criteria that would include specialists in the EHR incentive programs.
By allowing specialists to opt out of reporting certain measures because they do not apply to their areas of practice, and adding other clinical quality measures, specialists will more readily be able to attest to meaningful use criteria, EHRA said.
Furthermore, the addition of imaging and registry reporting menu options, and a proposed exemption for payment adjustments for not being meaningful users are supported by EHRA.
According to the EHRA's comments, however, including specialists in the EHR incentive programs could lead to physician licensing issues, additional registry fees, and the need to develop new standards for specialty areas of practice.
Certified EHR technology may not have the necessary technical capabilities to handle health information from specialists, EHRA said.
The HIMSS comments are available at http://www.himss.org/content/files/MU_Stage2_NPRM_HIMSS_final.pdf.
The Health IT Now Coalition's comments are available at http://op.bna.com/hl.nsf/r?Open=gdos-8u4sk3.
The EHRA comments are available at http://www.himssehra.org/docs/20120503_EHRACommentsCMSMU2NPRM.pdf.
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