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CHIME: Watch the Pace, Practicality of Stage 3 Meaningful Use

January 19, 2013

In comments submitted to the Health IT Policy Committee and the Office of the National Coordinator for Health IT (ONC) today, the College of Healthcare Information Management Executives (CHIME) called on regulators to reconsider the speed and scale for achieving Stage 3 meaningful use objectives by 2016.

Responding to a Request for Comment issued by the HIT Policy Committee in late November, CHIME urged the federal advisory committee to recommend thorough evaluations of what has been accomplished thus far in order to place realistic measures and objectives for the nation’s hospitals in Stage 3.

“We see no value in setting unrealistic performance thresholds or expectations before current evaluations of what we have accomplished have been undertaken,” CHIME said. “[E]very desirable EHR-related objective cannot feasibly be met by 2016, nor do we see any value in attempting the rushed adoption of various EHR uses by that time. Instead, verifiable and continuous progress should be the goal.”

“One of our main messages to regulators is that we shouldn’t look to cram everything into Stage 3,” said Pam McNutt, Senior Vice President and Chief Information Officer at Dallas-based Methodist Hospital System and member of CHIME’s Policy Steering Committee. “The modernization of America’s healthcare system is a decade-long progression. We need to make sure that the HIT Policy Committee is looking at more than just the Stage 2 measures and objectives when making recommendations to HHS; that’s why we strongly urged thorough evaluations of to-date accomplishments and progress.”

In response to measures and objectives under consideration for Stage 3 meaningful use, the organization of healthcare CIOs made the following recommendations:

* Actual and proven HIE operations and interoperability, combined with a standard and highly-reliable way to identify patients, is mandatory to achieve the goals of Stage 3, and even stage 2; Encourage that the time frames for Stage 3 be linked to and preceded by proven HIE capabilities.

* Ensure that EHR certification requirements yield vendor products that allow EPs and hospitals to fully and easily satisfy any meaningful use documentation and audit requirements—such functionality must be inherent to certified EHR technology; Urge that audit measures be standardized to be based clearly on the certification requirements, and not subject to auditor variation.

* To help mitigate disruption from discontinuity in the EHR vendor space due to vendor business failures, vendor consolidation, decisions not to seek certification or performance problems, consider protection or accommodation for hospitals and health professionals that must undertake such EHR product transitions at the same time that they are expected to progress from one stage of meaningful use to another.

Regarding clinical quality measures (CQM), CHIME noted that over the past several years, CMS, ONC and other agencies inside HHS have demonstrated an increasing ability to convene public and private sector stakeholders to harmonize disparate health IT system requirements, technical standards and disseminate best practices.

“Meaningful Use is, perhaps, the best example of such policy approaches,” the organization said. “However, CHIME believes that such harmonization with regards to CQMs is overdue – and we believe that time is of the essence.”

In several of the group’s responses to CQM questions, CHIME urged regulators to keep a handful of fundamental tenets in mind: future measure sets should always tie back to care delivery quality and clinical efficacy; they should be expansive enough to allow clinical flexibility based on population characteristics; and regulators across federal, state, local and private sector reporting organizations should convene to understand what collection and reporting requirements will allow for optimal care quality improvement.

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