Comments Highlight Concerns Over Stage 2 of CMS’ Meaningful Use Program

May 11, 2012

Judging by the extensive comments that have come in since CMS posted the Stage 2 proposal, stakeholders have plenty to say when it comes to how the rule will affect physician practices.

Providers, medical groups, and other healthcare players have had close to three months to digest the contents of CMS’ Stage 2 requirements for its meaningful use EHR incentive program. 

And judging by the extensive comments that have come in since CMS posted the rule - for which May 7 was the deadline - stakeholders have plenty to say when it comes to how the rule will affect physician practices.  

The newly released 63-page comments by the EHR Association, for starters, sheds light on some of dozens of adjustments CMS will need to consider when making its final rule.

The EHR Association in its comments said that while it supports clinical decision support intervention tools as a means of providing providers with clinically relevant information during the care process, the proposed requirements for Stage 2 need to be refined.

Leigh Burchell, vice president of government affairs for Allscripts and chair of the association’s Public Policy Leadership Workgroup, told Physicians Practice the proposal suggested that providers move from one clinical-decision support intervention to five. Though the association supports this, it believes that those interventions should be tied to the clinical quality measure reports required of the program participants, which the association does not support. 

Burchell said that the list of clinical quality measures providers will be able to choose from has not been finalized and is expected not to include sufficient measures for all specialists. She also pointed out that providers should be given the flexibility to change the clinical decision support interventions being applied throughout the year depending on dynamics specific to their practice and patient base. 

“Both clinical decision support and clinical quality measurement are valuable elements of the meaningful use program,” said Burchell. “But to mandate a tie between the two when the clinical quality measures list is still immature, as it will be in Stage 2, would be a limiting factor for many providers and shouldn’t be finalized as proposed.” 

Meanwhile, Healthcare Information and Management Systems Society (HIMSS), in its comments strongly suggested that the government incorporate a 90- to 180-day reporting period for Year 1 of Stage 2 in 2014. As part of the preparation for the Stage 2 final rule, HIMSS is encouraging HHS to continue reviewing and reassessing the timeline to maximize the amount of time providers have to prepare.

Comments from HIMSS also stated that quality measures should be utilized only if the standards and specifications supporting the quality measure have been tested and verified, and that there should be better alignment between federal and state quality reporting requirements.

To make the rule “reasonable and achievable,” the American Medical Association (AMA) proposed a number of tweaks that would benefit providers, including the elimination of “back dating the meaningful use penalty program” and establishing more hardship exemptions. The AMA also called for synchronizing and improving overlapping health IT and quality program requirements, and the establishment of an appeals process under both the meaningful use and e-prescribing programs.

"Overall, the proposed Stage 2 requirements need to provide more flexibility to foster widespread EHR adoption," said AMA Board Chair-elect and physician Steven J. Stack, in a press statement. "Physicians are at varying stages of implementing health IT into their practices and should get credit for making a good faith effort to meet the meaningful use requirements."