AHA, MGMA, HIMSS express concerns about Stage 3 proposals

As the deadline looms for submitting comments on the proposed rules for Meaningful Use Stage 3 and EHR Certification, several professional associations shared their criticism and recommendations and they have a lot to say.

HIMSS: The folllowing are the organization's top concerns and recommendations:

  • Decrease the prescriptive nature of the EHR Incentive program,
  • Increase focus on the substantial capabilities established earlier in the program, and
  • Reduce complexity in the 2015 Certification Criteria. 
  • 18 months is the minimum length of time needed between the final rules on Meaningful Use, certification and standards, and the start of any stage of Meaningful Use. An 18-month timeline allows stakeholders to help educate and prepare providers on the upcoming new stage. The current timeline for transitioning to Meaningful Use, Stage 3 in 2017 and 2018 does not include 18 months. 
  • HIMSS supports the work being done by CMS to align the EHR Incentive Program with other CMS quality reporting programs that also use certified health IT.  HIMSS believes such efforts will lessen the burden on providers.

HIMSS said MU is a “critical tool for enabling healthcare transformation,” and reiterated its long-standing commitment to interoperability: “HIMSS is committed to a culture in which IT is fundamental to transforming healthcare; improving quality of care, enhancing the patient experience, containing cost, improving access to care, and optimizing effectiveness of public payment.”

Read the full HIMSS comments.

MGMA: The organization said "we are very concerned about the direction proposed for the third stage of the Medicare and Medicaid Electronic Health Record (EHR) Incentive (meaningful use) ProgramWe believe that if the program logistics and meaningful use requirements proposed in the rule are not first delayed and then substantially modified, it could result in a failure to meet the goals outlined in the American Recovery and Reinvestment Act of 2009 (ARRA).

"The small number of successful Stage 2 participants is clear indication that the government has overstepped its charge. The program has become a significant administrative burden and is
proving to be counter-productive for medical groups seeking to deliver efficient patient care."
The following points are MGMA's summary of key issues and recommendation:
  • Finalization of Stage 3 should be delayed until the impact of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) is known and the meaningful use provisions
  • of MACRA are developed through regulation.
  • The requirements set forth on the April 2015 Stage 2 modification rule should be adopted for the years 2015-2019.
  • Finalization of Stage 3 should be delayed until there is significant and actionable data from EP participation in Stage 2 of the program.
  • At a minimum, no measure thresholds should be established prior to CMS fully evaluating the success rate of EPs in meeting the Stage 2 requirements.
  • Stage objectives and measures must be reasonable and not act as a disincentive for EPs to participate.
  • CMS should avoid significantly increasing measure thresholds from those proposed in the Stage 2 flexibility regulation.
  • No Stage 3 objective should require actions on the part of patient or other third parties in order for the EP to successfully participate in the program.
  • The full year reporting proposed in this rule should be replaced with consecutive 90-day reporting for all years of the program.
  • MGMA supports the proposed hardship exemptions and encourages CMS to create additional hardship categories.
  • MGMA encourages CMS and ONC to continue provider outreach efforts and supports continuation of these efforts for the third stage of the program.

Access MGMA's complete comments.

American Hospital Association: AHA, along with six other national hospital groups, has urged the Department of Health and Human Services to work with stakeholders to accelerate the infrastructure needed for health information exchange and Stage 3 Meaningful Use of electronic health records, and refrain from finalizing a Stage 3 rule at this time.
“We believe the creation of an efficient and effective infrastructure for health information exchange is essential to support the delivery of high-quality, patient-centered care and is a precursor to many of the proposed advances for Stage 3,” the organizations wrote. They said their commitment to the successful use of EHRs and electronic exchange of health information “remains strong. We believe that providing additional time for maturation of implemented technology and optimization to support Meaningful Use and other regulatory requirements is the right policy to keep all stakeholders focused on the activities that will support the better quality care for patients and for populations.”
America’s Essential Hospitals, the Association of American Medical Colleges, Catholic Health Association of the United States, Children’s Hospital Association, Premier healthcare alliance, and VHA Inc. also signed the letter.