CHIME questions timelines in CMS' EHR Incentive Program
The College of Healthcare Information Management Executives (CHIME) is questioning whether the current proposed regulations in the Centers for Medicare & Medicaid Services (CMS) EHR Incentive Program allot enough time for providers to achieve meaningful use before they are penallized.
CHIME's concerns were included in comments the association filed with CMS on the proposed regulations.
Those regulations outline an “all-or-nothing” approach to defining and achieving meaningful use that is too ambitious, does not take into account the need for flexibility by providers and does not reward incremental progress, according to the Ann Arbor, Mich.-based organization.
CHIME reported that it wants CMS to give providers until 2017 to adequately achieve all components for EHR implementation, develop an expanded suite of 34 core objectives and use an incremental approach that would deem a provider a meaningful user if it can achieve 25 percent of objectives by 2011, 50 percent by 2013, 75 percent by 2015, and substantially all by 2017.
Contending that the “[health] IT marketplace does not have the capacity to support the timeframe imposed by the proposed regulations,” CHIME noted that the lack of a certification approach is resulting in industry uncertainty regarding product certification and heightens time pressures that both providers and vendors are facing.
The college proposed that the final regulations extend the time frame during which Stage 1 meaningful use objectives will be used, and it asked CMS to adopt a “grandfathering provision” under which existing EHR systems that meet meaningful use objectives be accepted as certified for two years.
CHIME contend that quality reporting requirements in the proposed regulation are unrealistic at the early stages of the incentive program, and it asked for a delay in implementing quality reporting until 2012.
“While automated quality reporting is critically important to the meaningful use of EHRs, no EHR system in use today is able to automatically report the full set of (35) proposed measures,” the organization stated.
Recommendations were also made regarding computerized provider order entry, medication reconciliation, data submission to public health agencies and HIT functionality data submissions.
The 1,400-member organization stated it is seeking:
For more information, the executive summary from CHIME can be found here.
CHIME's concerns were included in comments the association filed with CMS on the proposed regulations.
Those regulations outline an “all-or-nothing” approach to defining and achieving meaningful use that is too ambitious, does not take into account the need for flexibility by providers and does not reward incremental progress, according to the Ann Arbor, Mich.-based organization.
CHIME reported that it wants CMS to give providers until 2017 to adequately achieve all components for EHR implementation, develop an expanded suite of 34 core objectives and use an incremental approach that would deem a provider a meaningful user if it can achieve 25 percent of objectives by 2011, 50 percent by 2013, 75 percent by 2015, and substantially all by 2017.
Contending that the “[health] IT marketplace does not have the capacity to support the timeframe imposed by the proposed regulations,” CHIME noted that the lack of a certification approach is resulting in industry uncertainty regarding product certification and heightens time pressures that both providers and vendors are facing.
The college proposed that the final regulations extend the time frame during which Stage 1 meaningful use objectives will be used, and it asked CMS to adopt a “grandfathering provision” under which existing EHR systems that meet meaningful use objectives be accepted as certified for two years.
CHIME contend that quality reporting requirements in the proposed regulation are unrealistic at the early stages of the incentive program, and it asked for a delay in implementing quality reporting until 2012.
“While automated quality reporting is critically important to the meaningful use of EHRs, no EHR system in use today is able to automatically report the full set of (35) proposed measures,” the organization stated.
Recommendations were also made regarding computerized provider order entry, medication reconciliation, data submission to public health agencies and HIT functionality data submissions.
The 1,400-member organization stated it is seeking:
- Reconsideration of the hospital-based professional provisions of the regulations that exclude some hospital-based ambulatory clinics from participating in the program;
- Clarification of certification guidelines for EHR systems, given that “the vast majority of EHR systems are not one product but instead incorporate different systems from multiple vendors;”
- Further explanation on how the EHR Incentive Program will be administered;
- Review of provisions regarding health information exchange and a recommendation to develop and widely use a national patient identifier; and
- Reassessment of impact analyses that “seriously underestimate the total cost of ownership for these systems, and overstate the amount of incentive payments in aggregate that will be paid if the proposed rules are implemented.”
For more information, the executive summary from CHIME can be found here.