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CHIME Comments on Meaningful Use

May 1, 2012

The College of Healthcare Information Management Executives (CHIME) submitted 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 IT (ONC) outlined 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, Eligible Hospitals and Critical Access Hospitals.

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,” Pam McNutt senior vice president and CIO at Dallas-based Methodist Health System, said.

“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,” McNutt, a member of CHIME’s Policy Steering Committee, said. “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.

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