HIMSS' Electronic Health Record Association (EHRA) has asked the Centers for Medicare & Medicaid Services to rescind a recent change to an answer to a frequently asked question (FAQ) that the association contends deviates from regulations.
In a July 2 letter to Elizabeth Holland, director of CMS' Office of eStandards and Services' Health IT Initiatives Group, and Elisabeth Myers, the office's policy and outreach lead, the EHRA points out that FAQ 8231 added a new restriction in its June 23 revision that was neither specified in the final rule nor previously mentioned in guidance. The FAQ addresses reporting of ONC test procedure for (g)(1) and (g)(2) automated measure calculation regarding actions taken before, during and after the applicable Meaningful Use reporting period.
The original FAQ, created in 2013, stated that the criteria for a numerator is not constrained in the electronic health record reporting period unless expressly stated for that measure, so actions may reasonably fall outside the reporting EHR timeframe, but no later than the date of attestation in order for patients to be counted in the numerator. Now the actions must also take place no earlier than the start of the reporting year. EHRA points out that different developers had taken different approaches to this, and say it's unfair to make some of them reprogram and recertify their products in the middle of a reporting year. The association asks that CMS rescind the change as quickly as possible or at least provide guidance and an explanation so that providers aren't penalized. Letter (.pdf)