The Healthcare Information and Management Systems Society sent a letter to HHS Secretary Sylvia Mathews Burwell arguing that a recent final rule that requires a full year of reporting for the meaningful use program in 2015 is "unrealistic" and could cause providers to leave the program, Health Data Management reports (Slabodkin, Health Data Management, 9/12).

Background

Under the 2009 economic stimulus package, providers who demonstrate meaningful use of certified electronic health records can qualify for Medicaid and Medicare incentive payments.

CMS' final rule gives providers an additional year to upgrade EHRs systems to meet requirements for Stage 2 of the meaningful use program. The delay was originally proposed in May after just four hospitals had attested to Stage 2.

In addition, the final rule provides additional flexibility by allowing eligible professionals, eligible hospitals and critical access hospitals to use the 2011 Edition certified EHR technology or a combination of 2011 and 2014 Edition certified EHR technology for the 2014 EHR reporting period.

Providers will be able to attest to meaningful use under the 2013 reporting year definition and use the clinical quality measures from 2013.

Providers will not be penalized for failing to move to meaningful use Stage 2 during the 2014 reporting period.

The final rule noted that the proposed changes are just for 2014 and that all eligible providers will be required to use the 2014 Edition of certified EHR technology beginning in 2015.

Further, CMS in the final rule said that it would delay the start date for Stage 3 from Jan. 1, 2016, to Jan. 1, 2017, giving MU participants more time to meet Stage 2 requirements and begin working towards Stage 3.

However, CMS in the final rule declined to offer a 90-day reporting period during any quarter for Stage 2 in 2015, which was urged by many stakeholders. Instead, the final rule includes a year-long reporting period for Stage 2 in 2015 (iHealthBeat, 9/2).

Details of HIMSS Letter

In its letter, HIMSS wrote that the "decision to require a full-year of reporting using 2014 Edition [certified EHR technology] in 2015 puts many eligible hospitals ... at risk of not meeting [meaningful use] for 2015."

In addition, the group noted that the timeline gives hospitals less than a month to use 2014 EHR technology before they would lose eligibility for meaningful use incentive payments and potentially be subject to decreased Medicare payment adjustments in 2017 (Murphy, EHR Intelligence, 9/12).

Specifically, HIMSS noted that many providers who had been attempting to meet the previous 2014 attestation deadline had to halt those efforts and change their systems in order "to meet the just-finalized 2014 requirement." HIMSS added that "too many technology and process changes are required in too-short a period" for the 2015 start dates (Health Data Management, 9/12).

HIMSS predicted that "large segments of the provider community will no longer participate" in meaningful use if the government requires a full-year reporting period in 2015.

HIMSS urged HHS to reevaluate its position on the 2015 reporting requirements, arguing that the agency should allow providers who are not in their first year of the program to report for any quarter during 2015 (EHR Intelligence, 9/12).