While generally supporting CMS' proposal to allow providers additional flexibility in attesting to meaningful use this year, the College of Healthcare Information Management Executives has recommended several changes to the program the organization believes will help providers meet the requirements while keeping the industry moving forward.
In a letter to CMS Administrator Marilyn Tavenner and National Coordinator Karen DeSalvo, MD, CHIME outlined several proposed changes:
1. CMS should adopt the proposed flexibility for 2014 attestation, with the clarification that providers will be able to meet requirements retrospectively in 2014. "For example, one new pathway would allow a provider who is scheduled for Stage 2 to use 2011 Edition CEHRT against 2013 Stage 1 requirements, though it is likely this option is only available for providers who can configure their technology to perform a retrospective query," according to the letter. "We ask CMS to explicitly bless this strategy as a viable way to take advantage of new flexibilities in the final version of this [proposed rule]."
2. CMS should allow providers to attest to meaningful use in 2015 during any three-month quarter to both provide flexibility for struggling providers and encourage providers that took advantage of exemptions or alternate routes to attestation in 2014 to rejoin the program.
3. CMS should remove the transition of care requirement from stage 2, as meeting this requirement depends on referring partners' technical abilities and has proved a roadblock for many organizations.
4. CMS should remove the "fully implement" requirement, to alleviate provider concerns their systems and workflows will not be good enough, and to not punish providers for circumstances beyond their control, such as limited exchange capabilities among referring partners for the transitions of care requirement.
5. CMS should finalize the one-year extension of stage 2 for providers that attested to stage 1 in 2011 or 2012, to give the agency time to learn from the experience of stage 2 attestation before stage 3 requirements are finalized.
"From day one, CHIME has been an adamant supporter of meaningful use, and we remain supporters to this day," said Russ Branzell, CEO of CHIME, in a statement. "Our comments and recommendations are pragmatic and meant to ensure that industry, government and taxpayer investments are properly managed. We are confident that if CMS makes these common sense changes, we can realize the benefits of a modern, connected healthcare system."
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