The ACC on June 15 submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed rule for aligning Stage 2 of the Electronic Health Record (EHR) Incentive Program, also called Meaningful Use, with the recently proposed Stage 3 rule.

The Stage 2 rule contains the proposed criteria that eligible professionals, eligible hospitals and critical access hospitals would need to meet in order to qualify for EHR incentive payments and avoid penalties for non-participation. In this newly proposed rule CMS attempts to reduce the reporting burden, eliminate redundant and duplicative reporting, better align the objectives and measures of meaningful use, and focus Stages 1 and 2 of the EHR Incentive Program on advanced use of EHR technology. Most notably, this proposed rule would change the Medicare and Medicaid EHR Incentive Program reporting period in 2015 to a 90-day period rather than a full-year reporting period, which the ACC has called for in numerous letters to the federal government.

In its comments, the ACC, which has been a long-time supporter of EHR adoption as a driver of improved patient care quality, applauded CMS for listening to stakeholders’ Meaningful Use concerns and proposing changes that will benefit providers and patients alike. “These proposals will allow providers the opportunity to achieve the levels of meaningful use of EHRs in the 2015-2017 reporting years that they have worked towards since joining the program along with those who are just joining the program,” said the College. “The modifications proposed lay a framework for progress towards a program structure that allows for the broad adoption and improved use of health IT leading to interoperable health information exchange.”

Given that several decisions hinge on deadlines for implementing the proposed objectives and measures of Stages 1 and 2, the College pushed CMS to issue a final rule as quickly as possible. Additionally, the ACC urged CMS to do the following:

• Adopt the proposed 90-day reporting period for 2015
• Grant participants as much flexibility as is feasible by expanding hardship exemptions
• Provide a 90-day reporting period option for first time meaningful users in 2016 and 2017 and for participants reporting to a new stage of the program
• Reconsider the constricting requirements of the Public Health Objective

“Providing the appropriate modifications to a program this far into the reporting year is not an easy feat and the College recognizes the amount of thought and work that went into the development of this proposal,” said ACC President Kim Allan Williams, Sr., MD, FACC. “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., Cost of Illness, Electronic Health Records, Federal Government, Meaningful Use, Medicaid, Medicare, Patient Care, Public Health, Quality Improvement, Reimbursement, Incentive

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