HIMSS EHR Association Submits Feedback On Meaningful Use Stage 2May 8, 2012
On Friday, May 4th, the HIMSS Electronic Health Records Association submitted its comments on Meaningful Use Stage 2 with CMS and the ONC.
The EHR Association responded to notices of proposed rulemaking (NPRM’s) from both the Centers for Medicare and Medicaid Services, related to meaningful use objectives and measures for providers’ use of certified EHRs, and the Office of the National Coordinator for Health IT, regarding EHR certification criteria and standards related to Stage 2.
Environmental Intelligence, a premier provider of complete Health IT services with expertise in EHR Implementation, supports all the feedback and recommendations that the HIMSS EHR Association submitted to CMS and the ONC.
Here are a few key highlights of the HIMSS EHR Association formal recommendations and feedback to the CMS NPRM’s for Meaningful Use Stage 2:
Topic/Section: MU2 Implementation Timing (FR 77 p.13703):
CMS proposes a one-year extension of Meaningful Use MU1 (MU1) for providers who attested successfully in 2011 because Meaningful Use MU2 (MU2) requires changes to both technology and workflow that cannot reasonably be expected to be completed in the time between the publication of the final rule and the start of the EHR reporting periods.
EHR Association comment:
The EHR Association strongly support this essential proposal. Many industry stakeholders, including the EHR Association, have emphasized the need to adjust the originally proposed timeline, as it did not allow sufficient time for safe development and implementation. Coordinated with the ONC proposed rule on standards and certification, this extension will positively affect all providers who will be pursuing meaningful use in FY/CY 2013, as they would have been responsible for implementing or upgrading to “MU2 certified” EHRs. The combined changes proposed by CMS and ONC with respect to meaningful use timing and certification will substantially reduce the problems that would have been created by the current timeline.
Topic/Section: Criteria for Selecting Clinical Quality Measures (FR 77 p. 13700, 13743, etc.):
For Eligible Providers, CMS proposes a set of clinical quality measures beginning in 2014 that align with existing quality programs, such as those measures used for the Physician Quality Reporting System (PQRS), CMS Shared Savings Program and the National Council for Quality Assurance (NCQA) for medical home accreditation, as well as those proposed under the Children’s Health Insurance Program Reauthorization Act, (CHIPRA) and under ACA Section 2701.
EHR Association Comment:
The EHR Association applaud CMS for its commitment to aligning measures among reporting programs for both the Eligible Providers and Eligible Hospitals/Critical Access Hospital program. The EHR Association urge CMS to also seek alignment in other areas of quality measurement, such as the technical specifications and data reporting methods. The EHR Association also call attention to the duplicate effort required of providers to collect data for both manually abstracted measures and eMeasures, and we ask CMS to consider ways to continue to reduce this burden.
Click here to read the EHR Association’s letter to the National Coordinator for Health IT Dr. Farzad Mostashari with their comments on the Meaningful Use Stage 2 NPRM’s.
Click here to read the EHR Association’s letter to the Centers for Medicare and Medicaid Services Acting Administrator Marilyn Tavenner, with their comments on the Meaningful Use Stage 2 NPRM’s.