Among CHIME's other recommendations:

• That actual and proven HIE operations and interoperability, combined with a standard and highly-reliable way to identify patients, be mandatory to achieve the goals of Stage 3, and even stage 2; Encourage that the time frames for Stage 3 be linked to and preceded by proven HIE capabilities.
• That officials ensure EHR certification requirements yield vendor products that allow eligible providers and hospitals to fully and easily satisfy any meaningful use documentation and audit requirements—such functionality must be inherent to certified EHR technology;  Urge that audit measures be standardized to be based clearly on the certification requirements, and not subject to auditor variation.
• That, in order to help mitigate disruption from discontinuity in the EHR vendor space due to vendor business failures, vendor consolidation, decisions not to seek certification or performance problems, officials consider protection or accommodation for hospitals and health professionals that must undertake such EHR product transitions at the same time that they are expected to progress from one stage of meaningful use to another.

As for clinical quality measures (CQM), the CHIME letter noted that over the past several years, CMS, ONC and other agencies inside HHS have demonstrated an increasing ability to convene public and private sector stakeholders to harmonize disparate health IT system requirements, technical standards and disseminate best practices. “Meaningful use is, perhaps, the best example of such policy approaches," it read. "However, CHIME believes that such harmonization with regards to CQMs is overdue – and we believe that time is of the essence.”

CHIME urged regulators to keep a handful of fundamental tenets in mind: future measure sets should always tie back to care delivery quality and clinical efficacy; they should be expansive enough to allow clinical flexibility based on population characteristics; and regulators across federal, state, local and private sector reporting organizations should convene to understand what collection and reporting requirements will allow for optimal care quality improvement.

“Even minute changes to specifications can present tremendous workflow and monetary burdens on providers,” said Liz Johnson, vice president of applied clinical informatics at Dallas-based Tenet Healthcare, in a statement. “A sensible approach to future measure set development allows for evolution in technology in a way that minimizes such burdens on providers. We need a concerted effort in the near-term that improves data collection, abstraction and reporting on current generation CQMs. This effort should include an absolute focus on harmonizing the current data specifications for similar measures."

[See also: ONC to solicit comments on MU Stage 3]