America’s Essential Hospitals called on the Centers for Medicare & Medicaid Services (CMS) to immediately provide much-needed flexibility for providers in the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs (also referred to as the meaningful use programs). The association submitted comments to CMS on the agency’s proposals to modify stages 1 and 2 of the meaningful use program for reporting years 2015 to 2017.
The meaningful use programs offer incentive payments to providers who adopt and meaningfully use EHRs and assess penalties on those who fail to do so. In our comments, we asked CMS to ensure the programs foster meaningful use without unnecessarily overburdening providers. The following are some of the specific comments included in the letter:
- CMS should immediately finalize its proposal to offer a 90-day reporting period for all providers in 2015, instead of the full-year reporting period that is normally required of returning providers.
- CMS should continue to allow providers attesting to meaningful use for the first time in future years to use a 90-day reporting period.
- CMS should finalize its proposal to lower the threshold for the patient electronic access measure, which has been difficult for providers because it is dependent on patients accessing their personal health information through a portal.
- CMS should not require all providers in the meaningful use programs to report on the same set of modified stage 2 measures and objectives beginning in 2015. Under this proposal, providers in their first year of the program would be held to the same standards as those who have multiple years of experience. Instead, CMS should allow providers to attest to the measures and objectives of the stage for which they were originally scheduled in a given year.
Contact Shahid Zaman, Esq., policy analyst, at firstname.lastname@example.org or 202.585.0124 with questions.