A cohort of 53 organizations including the American College of Radiology and the American Hospital Association sent a letter this week to Secretary of Health and Human Services (HHS) Kathleen Sebelius to provide “greater flexibility in meeting meaningful use.”
“We fully support the purpose of the American Recovery and Reinvestment Act of 2009 (ARRA) to encourage the adoption and use of EHRs and infuse stimulus dollars into the healthcare sector,” stated the letter. “We want to ensure, however, that the provisions of the statute are implemented in a manner that will remove barriers to and promote the widespread adoption of health IT.”
Stating that the current rules on meaningful use take an “all-or-nothing” approach, the coalition urged the Centers for Medicare and Medicaid (CMS) to require providers to implement a percentage or limited number of the meaningful objectives and offer providers greater flexibility in choosing which requirements to implement.
“The inflexible sets of 23 and 25 requirements would result in very few providers being able to meet the all-or-nothing approach, despite having adopted numerous EHR components,” the letter stated. The coalition also urged CMS to extend the meaningful use requirements to 2017, a transition they believe “would provide a more realistic adoption curve without changing the payment and penalty schedule established in law.”
To focus on clinical objectives, the letter asked CMS to drop the “check insurance eligibility electronically from public and private payers” and “submit claims electronically to public and private payers” proposed measures, which relate to administrative systems.
Because the coalition is concerned about CMS’s proposal to use Medicare provider numbers to distinguish hospitals for EHR incentive payment purposes, the coalition recommends that, “for purposes of the ARRA health IT incentives, CMS define a hospital as a discrete facility of service, so that individual sites of hospitals are eligible to separately qualify for the incentives. While CMS does not currently collect data by individual hospital site, it does have avenues through which it could do so, such as the cost report.”
To make reporting requirements less burdensome, the organizations recommended that CMS only require reporting of health IT functionality measures that can be generated directly from EHRs, with no need for manual chart reviews. “We also recommend that CMS postpone the requirement on submission of quality metrics until there is evidence that the means to capture the data from EHRs and submit the data to CMS is validated. Testing of these processes should take place in the initial years.”
The letter also advocated:
- Small physician practice representation on the Health IT Policy Committee;
- A feedback loop on program performance; and
- Greater attention to operational issues.
“We greatly appreciate the hard work of CMS in crafting the notice of proposed rulemaking under tremendous time pressures,” the letter ended. “We look forward to working [together] to ensure a successful implementation of the challenging program, and achieving an e-enabled healthcare system.”