The Premier healthcare alliance is the latest in a string of healthcare associations to submit comments in response to the proposed rule for Stage 2 meaningful use. The alliance urged the government to publish a final rule no later than August 2012 – or to extend Stage 1 for one more year.

Premier focused its comments on criteria impacting hospitals, including critical access hospitals.

The alliance spotlighted some key comments:

• Timeline. Premier supported CMS’ decision to extend Stage 1 through 2013, but strongly encouraged CMS to publish a final rule specifying Stage 2 requirements no later than August 2012.  Failure to publish a final regulation by August 2012 would seriously compromise the ability of the healthcare community to meet Stage 2 requirements beginning in 2014, officials contended. If CMS is not able to accomplish this, Premier recommended that Stage 1 be continued for an additional year, and that Stage 2 commence in FY/CY 2015. And, for the future, Premier urged CMS to publish a final rule specifying EHR meaningful use requirements no later than two years prior to the first year for the applicable stage of meaningful use.
• Multi-campus hospitals. Premier echoed its Stage 1 comments, urging CMS to modify hospital eligibility requirements to ensure that eligible hospitals with multiple inpatient facilities operating under one provider number are not prevented from earning incentives through the EHR Incentive Program for each inpatient facility.
• Core hospital meaningful use objectives and measures. Premier recommended changes to several hospital objectives and measures to ensure their appropriateness for EHs (eligible hospitals) and CAHs (critical access hospitals). Furthermore, Premier encouraged CMS not to adopt new EHR meaningful use core measures unless they have first been included as part of a previous menu set. This approach would allow both CMS and providers to gain some experience with a measure before determining not only whether the measure should be moved from menu to core, but also the appropriate specifications (for example, thresholds) for the core measure.
• Menu set of hospital meaningful use objectives and measures. In addition to recommending changes to the menu set of objectives and measures, Premier expressed its concern about the risk that many hospitals will be unable to meet the required two of four available measures. Premier urged CMS to carefully assess whether the menu set it intends to finalize is one that will include a sufficient number of feasible measures for the typical hospital. Inability to meet a menu set item should not generally be the reason for hospitals’ failure to qualify for EHR incentives or the reason they incur an EHR payment adjustment.
• Clinical quality measure reporting. Premier urged CMS in Stage 2 not to increase the number of measures that would need to be reported (from the final measure menu), but to instead continue to require the reporting of 15 clinical quality measures. Premier emphasized that in order to obtain certification of their EHR products, vendors should cover a sufficient number of CQMs (clinical quality measures) and domains, as appropriate for their particular systems and customers. Premier expressed its concern about the proposed requirement that hospitals report at least one measure from each of the six domains. For two domains, care coordination and population/public health, the proposed CQM menu includes only two measure options, which would offer hospitals too few choices in meeting a one-measure-per-domain requirement. Premier recommended that CMS require hospital reporting of at least one measure per domain only if a domain includes at least four measures from which to choose. Premier also included comments and recommendations on a number of the proposed hospital CQMs it believes are problematic.
• Payment adjustments for EHs not achieving EHR meaningful use. With respect to the payment adjustment in FY 2015 for EHs not meeting EHR meaningful use requirements, Premier strongly opposes CMS’ proposal of an FY 2013 reporting period. In its comments, Premier recommended two alternatives: 1. Under the first alternative, the reporting period for the FY 2015 payment adjustment would be FY 2015. For those hospitals failing to meet EHR meaningful use requirements in that year, Premier believes that the hospital cost report settlement process would provide an efficient and ready means for applying the penalty for FY 2015. 2. Under a second option, CMS would adopt an FY 2014 reporting period for all hospitals (not just first time meaningful users), and then apply a penalty for those failing to achieve meaningful use in that period during the second half of FY 2015 (perhaps at double the rate that would apply over a full FY).
• Exceptions for payment adjustments. Premier supports CMS’ proposed exceptions to the payment adjustments for EHs and CAHs, and recommended an additional exemption for hospitals whose incumbent EHR vendor has failed to obtain timely certification of the relevant EHR product.  Similarly, Premier recommended that an exception should apply to hospitals that find it necessary to change EHR vendors and whose new vendor ends up failing to obtain timely certification of the relevant EHR product.
  

[See also: CHIME asks for more prep time for Stage 2.]