The ACC on May 29 submitted comments to the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) on the proposed rule for Stage 3 of the Electronic Health Record (EHR) Incentive Program, also called Meaningful Use Stage 3. The rule, which was released on March 20, contains the proposed criteria that eligible professionals, eligible hospitals and critical access hospitals would need to meet in order to quality for EHR incentive payments and avoid penalties for non-participation. CMS’ stated objectives for the proposed rule are to increase simplicity and flexibility in the program while driving interoperability and focusing on patient outcomes in the MU program. CMS also makes it clear in the rule that it intends for its proposal to apply beyond EHRs to other categories of health information technology.

The ACC, which has been a long-time supporter of EHR adoption as a driver of improved patient care quality, recognized CMS and ONC’s efforts to ease the constraints and complexities established in Stages 1 and 2 of the program and their attempt to further clarify EHR certification. However, “Overall, the ACC believes the proposed requirements for Stage 3 set the bar for success too high,” the College wrote in its comments.  “The Meaningful Use criteria should encourage the appropriate, purposeful and accurate use of health IT solutions, rather than mandate completion of tasks based on a particular timeline.”

The College, pointing out that obstructed health information exchange can negatively impact the quality of patient care, offered the following recommendations to CMS and ONC to ensure flexibility in the program:

• Reestablish 90-day reporting periods for all first time meaningful users in 2018 and beyond, along with a 90-day reporting period for all providers reporting to Stage 3 for the first time
• Discontinue the pass-fail approach of the EHR Incentive Program and transition to assessing achievement on a sliding scale so participants can be provided credit for partially meeting performance thresholds
• Reassess the proposed thresholds of objectives five to eight to provide more realistic benchmarks
• Provide additional time to further develop electronic clinical quality measures (eCQMs) and allow for a period where participants can transition from their current clinical quality measures to eCQMs
• Remove requirements that hold physicians accountable for actions beyond their control
• Adopt a standard that will ease the movement of data from EHRs to registries
• Provide for an ample and thorough testing period with each new vendor development cycle
• Require EHR vendors to publish prices for each service a user may need
• Make public a list of complaints and failure rates for all future testing of certified EHRs

ACC President Kim Allan Williams, Sr., MD, FACC, concluded, “…while the proposals addressed here are far from perfect, the College recognizes the amount of thought and work that went into their development. However, the College has substantive concerns about the practicability, adaptability, deliverability, and ability of physicians to comply with the proposed Stage 3 requirements and 2015 edition of the standards, implementation specifications and certification criteria as described above. The College appreciates the opportunity to furnish input on this important issue and looks forward to the prompt issuance of the final rules.”

Get a deep dive of the proposed rule here.

Keywords: Centers for Medicare and Medicaid Services, U.S., Certification, Electronic Health Records, Meaningful Use, Medicaid, Patient Care, Registries

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