HIMSS to CMS on Meaningful Use Stage 2

...[W]e offer the following recommendations that are designed to maximize the number of EPs and EHs successfully attesting to the program’s requirements using a 2014 certified EHR, and keep our nation on the path toward health care transformation.

HIMSS strongly recommends that CMS:

1. Extend Year 1 of the MU Stage 2 attestation period through April 2015 and June 2015 for EHs and EPs, respectively. 

HIMSS reiterates our recommendation from our August 2013 Call to Action that asked HHS to launch Stage 2 on schedule, and extend Year 1 of the MU Stage 2 attestation period. In addition, as we await more details on the exception process, HIMSS recommends that CMS accept and process hardship exception applications before the final filing deadline, so EPs and EHs can have a sense of whether the exception parameters are applicable for their specific circumstances.

2. Establish itself as the unequivocal “Single Source of Truth” on program requirements.
 
To comprehensively understand the needs of EPs and EHs, CMS should immediately and greatly increase its listening sessions across the United States and overall outreach to the provider community. As your agency enhances its educational efforts on the provider side, it should rapidly translate for the EH and EP communities how providers who successfully attested were able to meet the reporting requirements.

For example, CMS should immediately publish “minimal necessary” use cases gathered from successful attesters for all the program objectives. Providers could use the identified examples and guidance from CMS to meet the most challenging objectives, such as view, download and transmit and transitions of care, in order to meet the requirements for MU Stage 2.

With regulatory and reporting pressures mounting on providers from several different fronts, CMS must make certain that providers are positioned to succeed in the EHR Incentive Program. Listening sessions across the nation could be leveraged to inform the creation of case studies gathered from those who have successfully navigated these competing priorities. Such listening sessions, and subsequently-published case studies, would be highly valued by stakeholders.

One of the major themes identified by research conducted by HIMSS over the past several weeks is the lack of a “single source of truth.” Stakeholders are experiencing tremendous frustration and confusion about where to find essential guidance, and who to believe about what. We understand CMS has revised Tip Sheets available that will take some of the confusion out of provider, hospital, and vendor preparation. CMS should also immediately release the updated attestation Tip Sheets to EPs, EHs, and vendors. The delayed release is feeding healthcare community concerns and confusion about “best approaches” to achieving requirements.

3. Simplify Clinical Quality Measure (CQM) requirements until standards and processes can support robust electronic reporting. 

HIMSS lauds CMS for its efforts to align quality measure sets across multiple CMS clinical quality reporting programs and tie payment to value. However, several critical issues still exist for quality reporting to truly improve the quality of care delivery while not making data collection an overly burdensome part of a workflow. Greater clarification and coordination in this area is imperative to addressing uncertainty.

CMS should take rapid action to ease and simplify the reporting requirements so that providers have options that suit their current workflows and technological capabilities, while easing their regulatory burden. HIMSS recommends CMS consider the variation in quality reporting methods from chart abstraction to electronic quality reporting. Further, HIMSS recommends that CMS provide education and outreach to the provider and hospital community to assist in this transition.

As an example, beginning in 2014, all EPs and EHs beyond their first year of meaningful use are being required to submit CQMs electronically. EHs can electronically report clinical quality measures directly from their EHR to meet the quality reporting component for both Meaningful Use and the Inpatient Quality Reporting (IQR) program. If some EH stakeholders choose to report for the IQR via chart abstraction, they must select from a different set of measures. Some of the measures are the same in both sets (with the paper measures retooled for use in EHR-based reporting), however an EH or EP can meet CQM reporting requirements for the IQR and Physician Quality Reporting System program while reporting on different CQMs than those reporting through the EHR. Continued efforts to advance flexibility in reporting will have a dramatic impact on EH and EP ability to report as alignment advances.

4. Launch association collaboration to “translate” program requirements.

As soon as possible, CMS should convene a stakeholder group of Subject Matter Experts to clarify specific program requirements through language that can be easily understood by most EPs and EHs. In addition to making it easier for stakeholders to understand, such language would also support HHS’ vision for the role of IT in healthcare transformation.

It appears that HHS’ dynamic vision of its role in healthcare transformation is not fully understood or assimilated at the facility, organization, or provider levels. Many stakeholders in the field experience frustration with existing language that is neither intuitive, nor written to be readily understood by EPs and EHs.

HIMSS, other non-profit associations, Regional Extension Centers, and other resource organizations should be invited to collaborate with CMS to remind the healthcare community of this larger vision, maintain the momentum of the MU program, and help providers and facilities understand and incorporate the program goals – namely, improved care and outcomes – as they adopt and implement certified EHR technology. HIMSS has the subject matter expertise to work collaboratively with CMS to provide such “translation services” that interpret – but not change – CMS’ guidance...

"Regional Extension Centers, and other resource organizations should be invited to collaborate with CMS"

Right. How about recommending re-funding the RECs? As I argued at HIMSS14.

"[CMS] Establish itself as the unequivocal “Single Source of Truth” on program requirements."

So, are we proposing that ONC be demoted on the HHS org chart? Maybe someone ought to apprise the FDA:

"We believe a limited, narrowly-tailored approach that primarily relies on ONC-coordinated activities and private sector capabilities is prudent." - FDASIA Health IT Report, April 2014

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More to come...