The letter to Dr. Farzad Mostashari, head of the Office of the National Coordinator for Health Information Technology at HHS, was signed by CHIME President and CEO Richard Correll and board Chairman George Hickman, the executive vice president and chief information officer of Albany (N.Y.) Medical Center.
The HIT Policy Committee advises the national coordinator on policy matters, including the meaningful-use criteria that hospitals, physicians and other “eligible professionals” must meet to qualify for incentive payments under the American Recovery and Reinvestment Act.
“We see no value in setting unrealistic performance thresholds or expectations before current evaluations of what we have accomplished have been undertaken,” a CHIME statement said. “Every desirable EHR-related objective cannot feasibly be met by 2016, nor do we see any value in attempting the rushed adoption of various EHR uses by that time. Instead, verifiable and continuous progress should be the goal.” Under the current timetable, Stage 3 meaningful-use requirements are expected to go into effect in 2016. Stage 2 requirements go into effect for hospitals on Oct. 1 this year, and for physicians and “other professionals” on Jan. 1, 2014.
CHIME also noted that health information exchange between providers' EHR systems is key to achieving Stage 3 and Stage 2 meaningful-use objectives, therefore it recommended that “the time frames for Stage 3 be linked to and preceded by proven HIE capabilities.”
In its statement, CHIME also urged the committee and the policymakers to which it reports “to keep a handful of fundamental tenets in mind” when setting Stage 3 rules for required reporting of clinical quality measures. Future required measures “should always tie back to care delivery quality and clinical efficacy; they should be expansive enough to allow clinical flexibility based on population characteristics; and regulators across federal, state, local and private sector reporting organizations should convene to understand what collection and reporting requirements will allow for optimal care quality improvement.”
Chip Kahn, president and CEO of the Federation of American Hospitals, said in an 11-page letter to Mostashari (PDF) that while the organization firmly supported State 2 meaningful-use criteria, “ we are concerned that so many of the objectives recommended in this Stage 3 (request for comment) will require significant additional investment by providers. We believe the time has come to assess the value of the requirements providers are already being asked to comply with for Stages 1 and 2 prior to adding substantial new requirements.”
To prove that the program is on target and producing useful results, “We strongly recommend that the ONC institute an initiative to assess the value of current meaningful use requirements and pilot-test proposed future requirements that require significant additional cost for providers before they are added to the program. At this critical juncture, FAH member hospitals would welcome the opportunity to work with the ONC to measure the promise and benefits of meaningful use.”
The AMA, in a recent 20-page letter to Mostashari from AMA Executive Vice President and CEO Dr. James Madara, also asked the CMS and the ONC to stop raising the bar on payment qualification criteria until an outside evaluator can take a look at the EHR incentive payment program and any issued raised is identified and publicly aired.
