The American Hospital Association (AHA) and the College of Healthcare Information Management Executives (CHIME), two of the biggest guns in the health IT industry, have formally expressed significant doubts about both the timing and the content of the proposed rule implementing Stage 2 of the electronic health record incentive program.
In a 68-page comment letter submitted to CMS April 30, AHA Executive Vice President Rick Pollack warned that the requirements for Stage 2 were not feasible, especially in light of the fact that more than 80 percent of hospitals haven't even attained Stage 1 Meaningful Use due to the high bar set and market factors, such as vendor capability. The AHA warned that elements of the proposed rule would "stand in the way of a successful program to support widespread adoption by all hospitals."
"Many of the proposals put regulatory requirements ahead of actual experience with these technologies--an approach that will likely have unintended consequences," Pollack wrote.
CHIME CEO Richard Correll and Board Chairman Drex DeFord expressed similar concerns about the proposed clinical quality measures, noting in a 46-page comment letter that the objectives were "overly ambitious."
The two organizations also agree with the delay of Stage 2 to 2013, but believe the start date should be pushed back even further. CHIME also recommended that in the first year of Stage 2 that providers should demonstrate Meaningful Use during a 90-day reporting period, similar to Stage 1, and require a full year reporting period only after the first payment year. The proposed rule requires that Meaningful Use be demonstrated for the full year throughout all of Stage 2.
The AHA expressed particular concern with the proposed objective on providing patients with the ability to access, download and transmit their protected health information via patient portals, citing security issues and claiming that it went "well beyond" current technical capabilities.
CHIME also submitted its comments on the EHR standards and certification criteria to ONC. The AHA has indicated that it will do so shortly.
Many more organizations and individuals are expected to comment on the proposed rule before the May 7 deadline.
To learn more:
- here's CHIME's comment letter to CMS (.pdf)
- read CHIME's comment letter to ONC (.pdf)
- here's the AHA's comment letter (.pdf)
- here are the proposed quality measures
- read the original rule (.pdf)
- here's where comments can be submitted