CHIME, which represents 1,400 healthcare CIOs across the country, is asking the government for more preparation time to demonstrate Stage 2 meaningful use, hoping to make sure the reporting is just so.

With the May 7 deadline looming for submitting comments to the federal government on Stage 2, CHIME sent letters April 30, to National Coordinator for Health IT Farzad Mostashari, MD, and to the Centers for Medicare & Medicaid Services, saying its members were concerned about the reporting period and also about CMS’ varying approach to clinical quality measures.

CHIME recommended that CMS allow hospitals, physicians and other eligible healthcare providers to demonstrate meaningful use of EHRs during a continuous 90-day EHR reporting period for their first payment year in Stage 2, an approach used in Stage 1.

“To allow adequate time for application development, provider adoption and testing, CMS should follow the precedent set in Stage 1,” CHIME officials wrote. “And similar to Stage 1, the EHR reporting period would be any continuous 90-day period within the first payment year of Stage 2 and a 365-day reporting period for all subsequent payment years within Stage 2.”

“We felt the approach taken in Stage 1 gave providers much-needed time to make sure the correct fields were populating and accurate meaningful use reports were being produced," said Pam McNutt, senior vice president and CIO at Dallas-based Methodist Health System. “We think a similar approach is needed for Stage 2 and beyond.”

“While we appreciate the delay of Stage 2 to Fiscal Year 2014, that decision was necessary, given that no one would be in a position to meet Stage 2 requirements beginning Oct. 1, 2012,” said McNutt, a member of CHIME’s Policy Steering Committee. “By giving providers flexibility through a 90-day reporting window, CMS can ensure that more Stage 1 meaningful users will become Stage 2 meaningful users.”

Quality measures reporting ‘daunting’
CHIME commented on the challenges involved with clinical quality measures in both letters to the ONC and CMS.

“The accurate reporting of quality measures is one of the most daunting challenges faced by providers today,” CHIME said. “Through our experiences with Stage 1, we found that although EHR products were able to automatically produce CQM [core quality measures] reports, the data was inaccurate and largely incomparable across different providers.”

As part of base EHR certification, CHIME urged ONC to require certification of EHR products to all CQMs needed to meet meaningful use in each setting.

“Certification should include all CQMs for associated settings, the letter stated. “And in order to minimize the costs of development and implementation, we recommend that ONC work with CMS to limit the total number of CQMs associated with each setting.”

“Quality measures are a vital component to increasing care efficiency, decreasing disparities and lowering costs,” said Elizabeth Johnson, vice president of applied clinical informatics at Tenet Healthcare and a member of CHIME’s Policy Steering Committee.

“It is clear that ONC recognizes the value of quality measures, but the state of quality measurement needs to mature.

HHS has been working to harmonize CQMs across its various reporting programs; however, more must be done to make the quality metrics consistent and meaningful.”

CHIME’s comments include suggestions on all 42 objectives and measures for both ambulatory and inpatient settings of care.

While CHIME supported nearly every measure meant to meet each objective, member CIOs were concerned with the lack and types of menu options.

“The menu set for both EPs (eligible providers) and hospitals is quite small in relation to the minimum number that would need to be met, thereby providing relatively few options for EPs and hospitals,” the letter stated. “A number of the proposed menu set objectives and measures also would have non-trivial cost implications for EPs and hospitals.”

CHIME urged CMS to carefully assess both the number and feasibility of menu options for the average physician practice or the average hospital in finalizing its rule for Stage 2.

[See also: Transaction technology critical to MU Stage 2]

[See also: Clock starts ticking for comments on MU rule]