The College of Healthcare Information
Management Executives (CHIME) recently submitted its comments on the proposed rules for stage 2
meaningful use, calling for more time to allow healthcare organizations to better prepare.
Comments filed with both the Centers for Medicare & Medicaid Services (CMS) and Office of
the National Coordinator for Health Information Technology (ONC) identified concerns related to the proposed
stage 2 EHR reporting period as well as CMS’ varying approach to clinical quality measures
(CQMs). CHIME also made recommendations on all 42 proposed objectives for eligible
professionals (EPs), eligible hospitals (EHs), and critical access hospitals (CAHs).
CHIME recommended that CMS allow EPs, EHs and CAHs to demonstrate meaningful use
during a continuous 90-day EHR reporting period for their first payment year in stage 2,
mimicking the approach used in stage 1.
“To allow adequate time for application development, provider adoption, and testing, CMS
should follow the precedent set in stage 1,” CHIME said. “And similar to stage 1, the EHR
reporting period would be any continuous 90-day period within the first payment year of stage 2
and a 365-day reporting period for all subsequent payment years within stage 2.”
“We felt the approach taken in stage 1 gave providers much-needed time to make sure the
correct fields were populating and accurate meaningful use reports were being produced—we
think a similar approach is needed for stage 2 and beyond,” said Pam McNutt senior vice
president and chief information officer at Dallas-based Methodist Health System.
“While we appreciate the delay of stage 2 to fiscal year 2014, that decision was necessary, given
that no one would be in a position to meet stage 2 requirements beginning Oct. 1, 2012,” said
McNutt, a member of CHIME’s Policy Steering Committee. “By giving providers flexibility
through a 90-day reporting window, CMS can ensure that more stage 1 meaningful users will
become stage 2 meaningful users.”
In both letters, to CMS and ONC, CHIME commented on the challenges involved with clinical
quality measures. “The accurate reporting of quality measures is one of the most daunting challenges faced by providers today,” CHIME said. “Through our experiences with stage 1, we
found that although EHR products were able to automatically produce CQM reports, the data
was inaccurate and largely incomparable across different providers.”
As part of base EHR certification, CHIME urged ONC to require certification of EHR
products to all CQMs needed to meet meaningful use in each setting. CHIME wrote that “certification should include all CQMs for associated settings. And in order to minimize the costs of development and implementation, we recommend that ONC work with CMS to limit the total number of CQMs associated with each setting.”
“Quality measures are a vital component to increasing care efficiency, decreasing disparities, and
lowering costs,” said Elizabeth Johnson, vice president of applied clinical informatics at Tenet
Healthcare and a member of CHIME’s Policy Steering Committee. “It is clear that ONC
recognizes the value of quality measures, but the state of quality measurement needs to mature.
HHS has been working to harmonize CQMs across its various reporting programs; however,
more must be done to make the quality metrics consistent and meaningful.”
CHIME’s comments include suggestions on all 42 objectives and measures for both ambulatory
and inpatient settings of care.
While CHIME supported nearly every measure meant to meet each objective, member CIOs
were concerned with the lack and types of menu options for EPs, EHs, and CAHs. “The menu
set for both EPs and hospitals is quite small in relation to the minimum number that would need
to be met, thereby providing relatively few options for EPs and hospitals,” the comment letter
said. “A number of the proposed menu set objectives and measures also would have nontrivial
cost implications for EPs and hospitals.” CHIME urged CMS to carefully assess both the
number and feasibility of menu options for the average physician practice or the average hospital
in finalizing its rule for stage 2.
To view CHIME’s comments to CMS, please visit www.cio-chime.org/advocacy/resources/download/CHIME_Comments-
A copy of CHIME’s letter to ONC can be found at www.cio-chime.org/advocacy/resources/download/CHIME_Comments-2014_Edition_EHR_Standards_and_Certification_Criteria_NPRM.pdf.
Source: The College of Healthcare Information Management Executives