CHIME, the College of Healthcare Information Management Executives, says the requirements for Stage 3 meaningful use are over the top, and its executives proposed several changes.

On the other hand, CHIME leaders were enthusiastic about CMS' proposal to shorten meaningful use reporting in 2015 from a full year to any continuous 90-day period.

The organization, which represents more than 1,400 CIOs and other health IT leaders, submitted its comments to the Centers for Medicare & Medicaid Services Wednesday. The deadline for comments is May 29.

HIMSS and several other organizations have not yet submitted their comments. A HIMSS spokesperson said, the organization planned to submit comments to CMS today.

CHIME told CMS, that its members recognizes the agency’s effort to streamline program participation through a reduced number of objectives and harmonized reporting periods, however Stage 3 proposals were "unworkable."

"Were all requirements finalized as proposed, we doubt many providers could participate in 2018 successfully," CHIME officials said in a letter. "And with so few providers having demonstrated Stage 2 capabilities, we question the underlying feasibility of many requirements and question the logic of building on deficient measures," CHIME executives wrote in the letter to CMS.

[See also: The good, the bad and the ugly of Stage 3 MU.]

Among the Stage 3 changes CHIME proposed were:

• A 90-day reporting period for the first year of Stage 3 compliance, at least for payment adjustment purposes;
• Modify requirements for and retain the 90-day reporting period for providers attesting to meaningful use requirements for the first time, whether in a Medicare or Medicaid context;
• Eliminate patient action thresholds for the care coordination objective;
• Reduce the number of required measures in multi-measure objectives, health information exchange and care coordination;
• Create hardship exceptions for providers switching vendors;
• Allow providers to take a 90-day reprieve during any program year for upgrades, planned downtown, bug fixes related to new technology or optimizing the use of new technology within new workflows; and
• Allow, in limited circumstances, paper-based means to achieve measure thresholds.

Patient action requirements related to care coordination and "unrealistic" thresholds for health information exchange requirements were of particular concern for CHIME. Also, the organization said it was troubled over the requirement that all providers must attest to meaningful use Stage 3 by 2018, regardless of prior participation and experience with the program.

"While we acknowledge policymakers' intention to make each Stage more difficult than the last, we are concerned with the strategy that envisions Stage 3 serving as both the apex of MU requirements and as a starting point for those providers with no experience at Stage 1 or Stage 2 of the EHR Incentive program," CHIME stated.

"We worry some of the objectives pose too great a stretch for seasoned meaningful users, let alone those who have never participated in the program."

[See also: CMS lays out vision for Stage 3 meaningful use and Reaction to Stage 3? Guarded.]

CHIME CEO and President Russell P. Branzell said though CMS has proposed limited flexibility for meeting objectives, many providers face a significant chance of falling short and incurring substantial penalties.

"In order to realize the network effects of meaningful use, we need as many providers as possible participating in the program," he said. "As proposed, this rule may do more to deter, rather than encourage, ongoing participation."

"We question the value of setting thresholds for technology and process not yet invented, let alone widely deployed in healthcare," added CHIME Board Chair Charles E. Christian, vice president of technology and engagement with the Indiana Health Information Exchange, in a statement. "From the heavy reliance on APIs to an assumption that patient-generated health data will flow in standardized ways, our industry has a long way to go if it is going to catch-up with this rule by 2018."

Other proposed regs

Separately, CHIME submitted comments on two other pending regulations, the ONC 2015 Edition HIT Certification Criteria NPRM and the CMS proposed rule to change meaningful use Stage 2 criteria.

In its comments on the proposed rule to modify meaningful use requirements from 2015 to 2017, CHIME gave CMS kudos for leading a series of changes to the program, specifically the provision to shorten the EHR reporting period in 2015 from 365 days to 90 days.

"The additional time afforded by this modification will help hundreds of thousands of providers meet meaningful use requirements in an effective and safe manner," CHIME stated. "Further, it will serve as positive incentive for those who optioned alternative pathways to meet MU in 2014 to continue their work in 2015 and beyond."

CHIME also supported modifications pertaining to patient electronic access, secure messaging & summary of care measures, stating that it opposes requirements that place accountability for patient behavior beyond what clinicians or providers can control, but called on CMS to address patient engagement more innovatively.

"As our industry continues the discussion of how best to engage the patient through technology, and how best to measure these efforts, we encourage CMS to think more innovatively around the concept of patient engagement, how to differentiate between those that do it well and those who do not, and how to incentivize laggards," CHIME stated.

CHIME opposed the proposed exclusion pathways associated with the public health objective and the requirement for bi-directional exchange for immunizations registries. CHIME urged CMS to revisit those provisions in Stage 3.