Multiple healthcare organizations hustled ahead of Monday's deadline to file comments on the proposed Stage 2 meaningful-use rules for the federally funded electronic health-records incentive payment programs under Medicare and Medicaid.
Among the submitters were the American Medical Association and 98 state and medical specialty societies in a joint, 37-page letter (PDF)
to CMS acting Administrator Marilyn Tavenner. Also commenting was the MGMA-ACMPE, in a 29-page missive (DOC)
The Federation of American Hospitals chimed in with two submissions, one to Tavenner (PDF)
—22 pages on the proposed Stage 2 meaningful-use rule, which was issued by the CMS in March—and the other to Dr. Farzad Mostashari (PDF)
, head of the Office of the National Coordinator for Health Information Technology at HHS—six pages of comments on the ONC's companion rule on the testing and certification of EHRs for use in the incentive payment program.
All three organizations asked the feds to lower various hurdles from the proposed Stage 2 meaningful-use requirements, which will kick in for hospitals beginning Oct. 1, 2013, and for physicians and other eligible professionals on Jan. 1, 2014.
The statement by the federation, which represents more than 1,000 for-profit hospitals, said the lessons learned from Stage 1, which began for hospitals Oct. 1, 2010, included recognition of “the high cost of adoption in terms of both capital expenditure and workflow disruption and the limited capacity on the part of vendors” all resulted in a pace of adoption that was “less than optimal for many providers.”
“We should move forward based on early experience from the field, focusing attention and available resources on key areas, including automation of quality measurement and reporting and health information exchange, where infrastructure and clarity of direction are severely lacking,” the FAH statement said.
The federation also asked Mostashari to ensure that EHRs tested and certified under the auspices of an ONC-led program can routinely produce the quality reports needed to meet the CMS' requirements.
"Since the launch of the certification program, we have been extremely concerned about reports from the field of vendor products being certified for electronic quality measurement that cannot produce measures as a byproduct of the care process," the federation letter said.
The AMA, et al., asked that any new measures proposed for Stage 2 be introduced as optional elements that physicians may select from a menu in contrast with a shorter list of mandatory “core” measures.
Both the AMA and the MGMA called on the CMS to harmonize the rewards and looming penalties for noncompliance in the EHR incentive program with those of separate and different rules and penalties for the physician quality reporting and e-prescribing programs also run by the CMS.
The disharmony between the EHR incentive program, which requires electronic prescribing, and Medicare's stand-alone e-Rx program, is a hot button issue, said Robert Tennant, senior policy analyst for the MGMA.
“We've not received more calls on any other topic than the e-prescribing program,” Tennant said. “There is no reason why somebody who is tested for being a meaningful user should be penalized for not being an e-prescriber.”
“We don't want a huge directional change for the program,” Tennant said. Still, “You don't want to raise the bar too high and create barriers to adoption.”
Among others, the Certification Commission for Health Information Technology, an ONC-authorized testing and certification body, has posted on its website a summary and its full comments to the ONC
on the testing and certification proposed rule. The American Health Information Management Association
also plans to post its comments to both the CMS and the ONC on Tuesday, according to an AHIMA spokeswoman.
The Healthcare Information and Management Systems Society also submitted comments on both rules
A statement by the Chicago-based trade association for health IT system users and developers said it "strongly suggests" that the government incorporate a 90- to 180-day reporting period for the first year of the Stage 2 criteria.