Both the Healthcare Information and Management Systems Society (HIMSS) and the American Medical Association (AMA) have weighed in on the Centers for Medicare & Medicaid Services' proposed rule allowing some flexibility in Meaningful Use attestation for 2014, welcoming the concept but expressing concern that they're not sufficient to help providers out.
HIMSS' July 17 letter echoed several of the comments made by other stakeholders such as the American Hospital Association and the Electronic Health Records Association, asking CMS to clarify and expand what it means to be unable to fully implement 2014 certified EHR technology in order to take advantage of the flexibility. It also requested that the final rule mirror the proposed rule as much as possible due to the "tight timeframes."
"[T]he nation needs this regulation," HIMSS said in its comments. "We remain committed to keeping the healthcare community moving forward on the path to interoperability that leads to information exchange and supports healthcare transformation. ... Unfortunately, with the timeline and implementation challenges that eligible professionals [EPs], eligible hospitals [EHs] and vendors continue to cite in preparation for MU Stage 2, HIMSS believes that this action is necessary."
HIMSS also recommended that the final rule align the 2014 reporting requirements for eligible hospitals with the fourth quarter of calendar year 2014, rather than the current fiscal year 2014, which ends in September, and allow the 2015 reporting period to start Jan. 1, 2015, and end Sep. 30, 2015.
The AMA's comment letter, dated July 21, took a different approach, pointing out additional concerns about the Meaningful Use program itself. The AMA reiterated its trouble with the program's "all or nothing" approach and asked for a pass/fail standard. It also asked that, in light of the timeframes, that the Meaningful Use hardship application deadline be extended until after the final rule is issued.
The AMA additionally found fault with the proposed rule's failure to align Meaningful Use reporting with PQRS reporting and it's favoring of early adopters and larger providers. It warned that without changes many physicians will simply be unable to move beyond Stage 1 of the program.
The comment period on the proposed rule closed July 21.