Stage 3 is of Meaningful Use is too ambitious, the College of Healthcare Information Management Executives (CHIME) says in comments submitted to the Centers for Medicare & Medicaid Services this week on the proposed rule. However, the group supports changes made to Stage 2 that shorten the reporting period to 90 days.
CHIME tells CMS that the proposals in Stage 3 are "unworkable," adding that they doubt providers could successfully participate in 2018, according to an announcement.
In addition, in its comments, CHIME says some changes it would like to see in the rule include:
- A 90-day reporting period for the first year of Stage 3 compliance, as well as for providers attesting to the program for the first time
- Lower required measures in health information exchange and care coordination
- Creation of hardship exceptions for providers switching vendors
- The inclusion of paper-based in some circumstances to meet thresholds
The organization adds that CMS should finalize the proposed rule only after the 2016 program year has been completed.
As for the proposed modifications for Stage 2, released in April, CHIME says that it "enthusiastically supports the proposed shortened EHR reporting period," in its comments to CMS. The group also approves of proposed changes for Patient Electronic Access, Secure Messaging & Summary of Care objectives.
Still, there are two proposals that CHIME takes issue with: The group doesn't support CMS's proposed exclusion pathways associated with the public health objective, which it says goes beyond what Stage 2 requires; and the group worries that changes to the attestation deadline may disallow providers from attesting before the end of 2015. It recommends CMS allow providers who can attest before January 2016 the ability to do so.
In additional comments sent to National Coordinator Karen DeSalvo this week, CHIME calls the Office of the National Coordinator for Health IT's Certification Program a "laudable goal," but says its scope may impact the availability of health IT modules for eligible professionals and eligible hospitals to demonstrate MU. CHIME says ONC should make certification optional for certain types of care or practice settings, while keeping current certification requirement for health IT modules intended to support EPs and EHs under Meaningful Use.