A proposed rule published in May by CMS and the ONC would give providers more flexibility in attesting to meaningful use during the 2014 reporting period.
Under the modified attestation schedule, providers that were not able to fully implement 2014 Edition certified EHR technology in time to successfully attest to meaningful use due to vendor delays 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 official comment period on the proposed rule ended Monday. In addition to the industry groups that weighed in on the proposal, more than 1,000 individual providers and hospitals left a comment for CMS about the proposed change.
While most commenters welcomed the additional flexibility, many hospitals used the forum to request additional changes to stage 2 and beyond.
Finalize proposed rule rule quickly
Because the last 90-day reporting period for hospitals for the 2014 attestation period began July 1, hospitals have already had to make a decision about whether to forge ahead with meaningful use. However, the last reporting period for physicians does not begin until Oct. 1, meaning integrated health systems like San Diego-based Scripps Health could still benefit. "Scripps is writing to urge you to finalize the proposed rule as quickly as possible to avoid further strain to our organization," writes Joseph Traub, MD, vice president and medical director of information services at Scripps.
Reduce 2015 attestation period from one year to 90 days
A number of hospitals, like Floyd Medical Center in Rome, Ga., asked CMS to continue the 90-day attestation period into 2015, anticipating the challenges that have made stage 2 difficult to reach will continue into next year. "We had vendor delays with the upgrade to our 2014 CEHRT and delays in the implementation of our patient portal," wrote Floyd Medical Center CIO Jeff Buda. "As a result, it has been difficult to reach the 5 percent patient adoption rate. For electronic transmission of the transition of care record, our vendor is still testing changes to allow this to happen successfully. We need more time in fiscal year 2015 for these stage 2 requirements to be completed successfully so that patient care quality and safety do not suffer."
Extend stage 2 for one year
Danville, Pa.-based Geisinger Health System was one of the commenters advocating for a one-year extension of meaningful use stage 2 to help providers meet all requirements and prepare for stage 3. "We agree with the need to for a successful implantation of patient engagements, interoperability and health information exchange requirements," wrote Charles Sawyer, MD, chief health information officer at Geisinger. "We also agree that data utilization from stage 2 participants will aid policy decision for stage 3."
More flexibility for summary of care requirement
Meaningful use stage 2 requires hospitals to exchange care summaries with other providers, but many commenters pointed out this requirement can only be met if neighboring and affiliated providers have the appropriate technology. "Many smaller primary care providers still do not have Direct addresses or the capability to receive Direct messages," writes C. William Hanson III, MD, vice president and CMIO of Penn Medicine in Philadelphia. So despite Penn's efforts to upgrade to the right technology to enable data exchange, "it is unlikely that will be able to achieve electronic transmission for 10 percent" to meet the requirement.
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