CHIME On Meaningful Use 3: Some Elements Are "Overly Ambitious"

By Megan Williams, contributing writer

CHIME is in favor of modifications to Meaningful Use (MU) Stage 2, but believes that in its current state, Stage 3 may be reaching too far.

The College Of Health Information Management Executives (CHIME) took advantage of the Centers for Medicare and Medicaid Services’ (CMS) recent request for industry comment and submitted a letter with their opinion on both MU Stages 2 and 3 on May 26. The letter (available here) thanked CMS for the opportunity to weigh in and then proceeded to outline the organization’s take on the final two Meaningful Use initiatives.

Recommendations

CHIME acknowledged the inventive program’s role in increasing EHR (electronic health records) adoption and upgrading antiquated workflows. At the same time, it stressed the heavy demands placed on healthcare providers and IT solutions providers partners. It also included a list of recommendations to help the industry smooth the transition:

• creating a 90-day reporting period for the first year of compliance with Stage 3 guidelines, at the very least for payment adjustment purposes
• adjusting these guidelines for first time attesters
• eliminating patient action thresholds for care coordination objectives
• cutting back on the number of mandatory measures in objectives with multiple measures, HIE, and care coordination
• creating hardship exceptions for providers that are switching vendors
• granting healthcare providers the option of a 90-day reprieve during any program year for planned downtime, upgrades, and bug fixes related to implementing new technology or optimizing new technology within new workflows
• Allowing paper-based means to achieve measure thresholds in certain circumstances

Defining Meaningful Use

The letter also suggested that CMS consider a single definition of MU that relies on outcome quality measures and participation in proxy programs (it uses the Million Hearts campaign as an example) or instead reduces compliance burdens over the long-term. It also weighs on the sustainability of the program while again acknowledging the overarching goals of MU: “We support the notion that full reimbursement should be contingent on use of modern technologies and techniques, but the year-over-year compliance costs of participating in the Medicare and Medicaid EHR Incentive program are simply unsustainable, especially in the context of other HHS regulatory requirements and departmental goals.”

A Suggested Extension

CHIME also suggests that CMS postpone finalizing the proposed rule until after the 2016 program year. They base this suggestion on the need of new technologies (like APIs and FHIR) to meet objectives. They acknowledge the importance of such technologies, but consider them “untested” and “unproven” in healthcare and warn against too much reliance on them until they are further developed.