ACC Comments on Meaningful Use Stage 3 and 2015 CEHRT

The ACC on Dec. 15 submitted comments to the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator (ONC) for Health Information Technology (IT) regarding two final rules that were released in October. The first set of comments addressed Stage 3 of the Electronic Health Record (EHR) Incentive Program (also known as Meaningful Use or MU), and the second set pertained to the 2015 Health IT Certification Criteria.

Meaningful Use Stage 3

In its comments on Stage 3 MU, the College stressed its long-time support of EHR adoption as a driver of improved patient care quality, but warned that the quality of patient care could be weakened due to “impeded health information exchange and the subpar usability of EHRs.” The ACC made the following recommendations to CMS:

  • Refocus the program on interoperability, usability and outcomes rather than the processes of capturing and reporting data
  • Discontinue the pass-fail approach of the EHR Program and transition to assessing achievement on a sliding scale so participants can be provided credit for partially meeting performance thresholds
  • 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
  • Reassess the finalized thresholds for the measures of objectives four-seven to provide more realistic benchmarks
  • 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
  • Grant participants as much flexibility as is feasible by expanding hardship exemptions

“Overall, the ACC believes the finalized requirements for Stage 3 set the bar for success too high,” said the ACC. “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.”

Given that MU will be included under the Merit-Based Incentives Payment System, part of the Medicare Access and CHIP Reauthorization Act of 2015, as early as 2017, the ACC urged CMS to reopen Stage 3 of MU so necessary changes to program can be made. The College noted that in order to ensure that all physicians can meet the MU requirements and to set appropriate measures and thresholds, the Agency should evaluate data from providers’ experience under the original Stage 2 rule and the new Stage 2 Modifications rule.

Read the full Stage 3 MU comment letter.

2015 Health IT Certification Criteria

Since the MU rules and the EHR certification criteria are intricately linked, the College also submitted comments to ONC regarding their finalized 2015 Health IT Certification Criteria. The ACC expressed support of creating a nationwide health information infrastructure that encourages interoperability and positively impacts patient outcomes and population health.

“In order to establish such a critical infrastructure many changes in the health IT certification process have occurred,” said the letter. “The ACC appreciates ONC responding to our calls for increased usability, product transparency, interoperability, data portability, and registry participation in the final rule…”

The comments also addressed patient-generated data, post-market surveillance, and unique device identifiers.

Read the full Health IT Certification Criteria comment letter.

Keywords: Achievement, Benchmarking, Centers for Medicare and Medicaid Services (U.S.), Certification, Electronic Health Records, Meaningful Use, Medicaid, Medical Informatics, Medicare, Motivation, Patient Care, Physicians

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