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HAP Letter to Congress in Support of Flex-IT Act

September 24, 2014

Dear Members of the Pennsylvania Congressional Delegation:

On behalf of The Hospital & Healthsystem Association of Pennsylvania (HAP), which represents approximately 240 member institutions, including 125 stand-alone hospitals and another 120 hospitals that comprise 32 health systems across the state, I am writing to express our support for H.R. 5481, the Flexibility in Health IT Reporting (Flex-IT) Act.

The bill would provide critical flexibility for hospitals and health care providers to meet meaningful use requirements for electronic health records (EHR) in fiscal year 2015.

The intention of the meaningful use requirements is to ensure hospitals and health care providers are using certified electronic health record (EHR) technology that will improve quality of care, care coordination and patient engagement.

Pennsylvania hospitals have eagerly embraced the charge of using technology to promote better health outcomes and population health management, and to empower consumers.

Despite best efforts to comply, the current regulatory timeline for the delivery, installation, and implementation of 2014 Certified Edition EHR technology has posed significant challenges. Due to delays in the certification process, there have not been sufficient certified products offered by vendors which has impacted hospitals ability to attest to meaningful use.

Even using certified products, challenges remain with sharing data and interoperability within hospitals and across settings. In fact, many physicians and hospitals are struggling with implementation.

H.R. 5481, the Flex-IT Act would provide targeted relief by shortening the 2015 reporting period to 90 days from the current year-long requirement for Medicare and Medicaid EHR Incentive Program hospitals using the 2014 Edition Certified EHR.

Without this additional flexibility, the vast majority of Pennsylvania hospitals are required to meet all Stage 2 requirements on October 1, 2014.

Through May 2014, CMS has not publicly identified any Pennsylvania hospitals which have been able to meet Stage 2 requirements using 2014 Edition Certified EHR technology. We are aware of only a few Pennsylvania hospitals that have attested to meaningful use using 2014 Edition Certified EHRs.

Many Pennsylvania hospitals and physicians are dependent on new 2014 meaningful use flexibility provided by CMS to maintain their meaningful use status in 2014. Unfortunately, CMS provided no meaningful use flexibility for 2015.

In Pennsylvania, HAP supported the creation of the Pennsylvania eHealth Partnership Authority to enable health information  exchange (HIE) among health care providers. Collectively and individually hospitals and health systems across the state are working to leverage technology to transform the delivery of care.

This legislation provides common-sense relief to allow for the safe and effective implementation of new technologies. 

Thank you for your consideration.

Sincerely,

Andy Carter
President and Chief Executive Officer

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