The AAMC May 29 submitted two separate comment letters in response to the Centers for Medicare and Medicaid Services (CMS) March 30 proposed rule on meaningful use Stage 3 and the Office of the National Coordinator for Health Information Technology’s (ONC) proposed rule on the 2015 Edition Health Information Technology (health IT) Certification Criteria (CEHRT).
AAMC’s comments to CMS focus on proposed aggressive requirements and timelines, particularly regarding the minimal data currently available on Stage 2. Additionally, comments to the ONC focus on increased vendor transparency and accountability, improved interoperability, and expanded data collection on social, psychological, and behavioral issues, including data collection to improve care for veterans and their families.
The AAMC urges CMS to delay finalizing Stage 3 both to obtain more experience with Stage 2 and to determine how meaningful use will be incorporated into the Merit-based Incentive Payment System (MIPS). The Medicare Access and CHIP Reauthorization Act of 2015 directs the Department of Health and Human Services (HHS) to create a MIPS that combines meaningful use with the existing Physician Value-based Modifier and Physician Quality Reporting System programs.
To ensure coordination across programs and avoid duplicative or contradictory policies, AAMC suggests CMS delay finalizing Stage 3 until the MIPS program has been designed. While MIPS only applies to eligible professionals (EPs), the AAMC encourages CMS to keep the meaningful use requirements for hospitals and physicians aligned.
The AAMC also makes several key recommendations to CMS regarding the meaningful use Stage 3 rule, including that CMS:
- Finalize the proposal to align the hospital reporting period with the calendar year, but only beginning in 2017;
- Not finalize a proposal that all providers be required to meet meaningful use Stage 3 in 2018;
- Provide additional flexibility for 90-day reporting periods beyond 2015;
- Provide a group reporting option for EPs; and
- Not finalize a proposal prohibiting paper-based formats from counting for certain measures.
CMS’ Stage 3 proposal consists of eight objectives, each with accompanying measures. The AAMC argues that several measures are too aggressive and believes it is premature to impose these proposed requirements. The AAMC objects to measures that require actions by patients, such as using secure messaging, as the provider has no ability to control whether or not patients will comply.
Regarding proposed changes to the clinical quality measures (CQMs), the AAMC urges CMS not to implement a requirement that hospitals and EPs electronically submit quality data starting calendar year (CY) 2018. The AAMC also encourages further alignment of CQM reporting between the EHR Incentive Program and other hospital and EP program requirements.
In regards to the CEHRT proposed rule, the comments highlight the importance of health IT in improving patient care and notes that AAMC members are committed to devoting considerable resources while adopting and advancing health IT. While technology continues to develop, the AAMC believes ONC has a responsibility to minimize disruption that could impede the delivery of efficient healthcare by harming provider-patient interactions.
The AAMC strongly supports ONC’s efforts to increase accountability and transparency in health IT to maximize the quality of care and inform decision-making processes. Additionally, the AAMC supports ONC’s inclusion of social, psychological, and behavioral data in the clinical record, as this would offer significant opportunity for academic medical centers and the health system at large to improve community health, better manage patient population health, and conduct health equity research.
CMS additionally issued a proposed rule modifying the meaningful use program for 2015-2017. Comments are due June 15.