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AAMC Submits Comments on CMS-ONC Proposed Changes to EHR Incentive Program for 2014

July 25, 2014—The AAMC July 21 submitted comments  on a Centers for Medicare and Medicaid Services (CMS) and Office of the National Coordinator (ONC) for Health Information Technology proposed rule that would make changes to the Medicare EHR Incentive Program, also known as Meaningful Use (MU).

The proposal would adjust the MU timeline and allow providers flexibility in how they demonstrate MU in 2014 [See Washington Highlights, May 23]. While the AAMC generally supported the proposals, the Association suggests some revisions to support even more flexibility in meeting the MU standards.

Under the proposed rule, CMS and ONC would allow providers to continue to use 2011 edition certified electronic health record technology (CEHRT) to meet stage 1 objectives, a combination of 2011 and 2014 CEHRT to meet stage 1 or stage 2 objectives, or 2014 edition CEHRT to meet stage 1 or stage 2 objectives. If a provider chooses to use only 2011 CEHRT or a combination of 2011 and 2014 CEHRT, they must attest that they could not fully implement 2014 CEHRT due to “availability delays.”

The AAMC letter expresses support for the added flexibility of the proposal, but recommended that the attestation requirement be removed because it is unclear what would constitute “availability delays.” While providers may have the technical capabilities of 2014 CEHRT the actual implementation of functionalities and integration into workflows is extremely difficult for organizations as large and complex as academic medical centers. The letter also states that providers may be unfairly targeted for audits due to the lack of a clear definition of “availability delays.”

Under the proposal, hospitals and eligible providers (EPs) that first demonstrated MU in 2011 and 2012 would not begin stage 3 until 2017, one year later than the previously established timeline. The AAMC recommends that CMS and ONC extend the delay of stage 3 beyond one year due to concern that providers will not have enough time to prepare for the additional requirements that stage 3 will bring. CMS and ONC are already aware of the many difficulties that providers have had in meeting stage 2 requirements, with their data showing only a tiny number of hospitals and EPs having successfully attested to stage 2 requirements thus far.

In addition, the AAMC suggests CMS and ONC revisit the policy of requiring full-year reporting for 2015 as providers that choose to take advantage of this flexibility will very likely not be in a position to successfully report a year’s worth of data in 2015.

The AAMC letter also recommends that CMS-ONC allow providers to report data for any three month reporting period in 2015.


Evan Collins, MHA
Specialist, Clinical Operations and Policy
Telephone: 202-828-0552


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