The College of Healthcare Information Management Executives, which represents more than 1,400 CIOs and IT leaders, has urged CMS and ONC to make some changes – and add some flexibility – to Stage 2 meaningful use. 

It made its plea on June 27, days before the government released the numbers of providers that had managed to achieve Stage 2. And the numbers were underwhelming, perhaps raising worries even higher. 

More flexibility is needed because changes proposed for the incentive program were only first released in late May, limiting the amount of time providers have to react to them, CHIME executives wrote in comments submitted to CMS and ONC on June 27.

"CHIME supports the new pathways as defined in the proposed rule," the letter reads. "We believe these options will provide needed flexibility for EHR optimization, encourage continued participation in the program and help maintain the upward trajectory of EHR adoption in the US."

One of CHIME's main requests is that the Centers for Medicare & Medicaid Services allow providers to choose any three-month quarter for an EHR reporting period in the next federal fiscal year or calendar year to qualify for meaningful use in 2015 instead of reporting a full year of data to qualify for incentives, as the program requires.

"We believe this change will have a dramatically positive effect on program participation and policy outcomes sought in 2015," CHIME officials wrote. "The additional time afforded by this modification would help hundreds of thousands of providers meet Stage 2 requirements in an effective and safe manner."

"We are grateful for the agencies' acknowledgement that 2014 has been an extremely challenging year for the industry," said CHIME President and CEO Russell P. Branzell.  "The new pathways created by this NPRM will enable many hospitals and physicians to capitalize on progress made to date. However, the benefits of this new flexibility will be immediately lost if 2015 reporting requirements are not tempered. Carrying forward the 2014 policy requiring providers submit data covering one quarter of their choosing in 2015 is common sense."

Additional flexibility is needed because of the continued industry-wide strain to implement information technology in time to meet ongoing requirements of the program, CHIME noted in the letter.

"Because there is such limited capacity for the industry to absorb ongoing technology upgrades and process changes, CHIME implores CMS to allow 3-month quarter EHR reporting options in 2015."

CHIME also asked that the agencies delete ambiguous attestation requirements related to the definition of "fully implemented" Certified EHR Technology.

"A number of CHIME members have indicated their apprehension to take advantage of the new pathways created by this NPRM (because of) how this proposed rule defines 'full implementation' of CEHRT since the examples do not adequately represent their situation," CHIME stated.

Audit anxiety

"Given the industry's experience with meaningful use audits, there is a lot of anxiety over how such a requirement would be validated," said CHIME Board Chair Randy McCleese, vice president of information services and CIO at Moorhead, Kentucky-based St. Claire Regional Medical Center.

"The fear generated by meaningless audits can be crippling for small and rural organizations like ours." McCleese said in a news release. "Ambiguity in what constitutes 'full CEHRT implementation' defeats the primary intent of this NPRM – namely, to encourage continued participation in the program."

Overall, CHIME believes "these new pathways will provide much-needed relief to hundreds of thousands of providers struggling to meet MU requirements in 2014, due to circumstances beyond their control," but CHIME is asking agencies to "explicitly state its intentions to let providers meet MU requirements retrospectively in 2014, if they are able."

In the letter, CHIME stated its support for the one-year extension of Stage 2 for providers that first qualified as meaningful users of EHR technology in 2011 and 2012.

"This is a necessary extension to give policymakers time to evaluate past experience and incorporate lessons learned into the third stage of meaningful use," according to the letter.

"From day one, CHIME has been an adamant supporter of meaningful use, and we remain supporters to this day," added Branzell. "Our comments and recommendations are pragmatic and meant to ensure that industry, government and taxpayer investments are properly managed. We are confident that if CMS makes these common sense changes, we can realize the benefits of a modern, connected healthcare system."