The American Hospital Association has written a letter to CMS Administrator Marilyn Tavenner and National Coordinator Karen DeSalvo, MD, asking the departments to quickly adopt a proposed rule that would allow providers that have encountered vendor delays additional flexibility in attesting to meaningful use.
Under the proposal, providers that were not able to fully implement 2014 Edition certified EHR technology in time to successfully attest to meaningful use would be able to use 2011 Edition CEHRT or a combination of 2011 and 2014 Edition to attest to either stage 1 or stage 2. Providers would also be able to attest to meaningful use under the 2013 reporting year definition and use 2013's clinical quality measures.
The proposed flexibility was welcomed by providers and stakeholders, though the timeline of the proposal itself has created uncertainty. The public comment period on the proposed rule is 60 days from the May 20 post date and the final meaningful use reporting period for hospitals for 2014 begins July 1, meaning executives may have to make a decision about attestation before they know for sure the fate of the proposed rule.
In the letter, Linda E. Fishman, AHA's senior vice president of public policy analysis and development, echoes these concerns.
"The last-minute nature of the proposals poses significant risk and operational challenges to hospital leaders, who must make significant and consequential decisions about what actions to take to meet meaningful use during the last possible reporting period," she said in the letter. "[H]ospitals are essentially asked to act on faith that the agencies will finalize these proposals as written — while risking that they may not — without the benefit of a later reporting period to conform to more stringent final rules."
The letter urges CMS and ONC to finalize the proposal and give hospitals as much time as possible to chart a course of action.
The letter also looks ahead, asking the departments to recognize 2015 may also be a "transition year" and a time when providers need additional flexibility, and to learn from stage 2 struggles before setting a start date for stage 3.
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