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ACCC Submits Comments to CMS about Meaningful Use Criteria of EHR Technology and EHR Incentive Program
On March 2, 2010, the Association of Community Cancer Centers submitted comments to the Centers for Medicare & Medicaid Services (CMS) regarding the interim final rule that specifies the initial set of standards, implementation specifications, and certification criteria for electronic health record (EHR) technology. ACCC voiced a number of concerns. Overall, ACCC believes that there are too many criteria proposed for Stage 1, that some of the proposed criteria are overly demanding, and that the proposed criteria may mean that relatively few eligible professionals and eligible hospitals would benefit from the Health information Technology (HIT) stimulus dollars approved under the American Recovery and Reinvestment Act.
ACCC noted that CMS has estimated that 47 to 79 percent of eligible professionals and an unspecified number of hospitals could face Medicare penalties in 2015 for failing to meet EHR meaningful use criteria. "We find this estimate troubling and we believe it suggests that the meaningful use criteria envisioned by CMS are overly ambitious," ACCC noted in its comments.
ACCC also urged the Office of the National Coordinator (ONC) to pay particular attention to the comments submitted by EHR vendors regarding the initial set of certification criteria. "Both ONC and CMS need to have reasonable expectations with respect to EHR vendor capabilities lest overly ambitious regulatory requirements significantly delay the availability of EHR technology," ACCC noted.
Further detailing its concerns, on March 2, 2010, ACCC also submitted comments to CMS about the Electronic Health Record Incentive Program.
CMS envisions a phased approach to defining meaningful use with three stages, but the proposed rule only addresses meaningful use criteria under Stage 1. CMS plans to propose the Stage 2 criteria by the end of 2011 (that is, in time for the 2013 payment year) and the Stage 3 criteria by the end of 2013 (in time for the 2015 payment year). For Stage 2 meaningful use criteria, CMS announces its intent to build up several functionality measures, including requiring:
- the electronic transmission of CPOE-entered orders;
- the incorporation of the full array of diagnostic test data into EHR as structured data, including radiology and nuclear medicine tests (rather than only clinical lab test results);
- increased exchange of electronic and structured data (rather than unstructured data); and 4) actual electronic submission of data, such as syndromic surveillance data, to public health agencies (rather than only the performance of a capability test).
ACCC believes that the proposed meaningful use criteria for Stage 1 are far too ambitious and urged CMS to re-examine its plans for Stage 2 and Stage 3.
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