Comment Letter to CMS on Proposed Stage 3 Meaningful Use Requirements
May 29, 2015
Andrew M. Slavitt
Centers for Medicare & Medicaid Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W., Room 445-G
Washington, DC 20201
Re: CMS-3310-P, Medicare and Medicaid Programs; Electronic Health Record Incentive Program-Stage 3 Proposed Rule
Dear Mr. Slavitt:
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, we appreciate this opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) proposed rule defining “meaningful use” of electronic health records (EHR) for Stage 3 of the Medicare and Medicaid EHR Incentive Programs.
Pennsylvania hospitals support the long-term goal of the EHR incentive programs, and they have been working diligently to implement new health information technology to improve the quality and coordination of care for patients.
While the Stage 3 proposals offer promising ideas that could further health information exchange and support greater patient engagement, we do not yet have sufficient experience at Stage 2 to be confident that the proposals for Stage 3 are feasible and appropriate.
In addition, the standards and information exchange structures needed to support many of the Stage 3 requirements are not yet mature enough to be included in regulation.
Furthermore, Stage 3 proposals such as relying on third-party applications to access sensitive patient data in EHRs may be a successful mechanism for the exchange of patient data information, but they raise important questions about patient privacy and information security that must be carefully considered.
Therefore, HAP urges CMS to refrain from finalizing a Stage 3 meaningful use rule at this time. Instead, the agency should evaluate the experience in Stage 2 while accelerating the availability of mature standards and the infrastructure needed for efficient and effective health information exchange.
For most hospitals and the vast majority of physicians, 2015 will be the first year at Stage 2 of meaningful use. The transition to new technology supporting Stage 2 has been a challenge for providers due to lack of vendor readiness, mandates to use untested standards, insufficient infrastructure to meet requirements to share information, and compressed timelines.
It also has proved extremely expensive—the American Hospital Association (AHA) estimates that between 2010 and 2013 hospitals in the United States collectively spent $47 billion each year on information technology.
We greatly appreciate the changes CMS has proposed in a separate modification rule for 2015 to 2017 that would accommodate some of the challenges, such as a shorter reporting period in 2015.
However, the need for those changes in the middle of a program year underlines the importance of ensuring that policies are feasible before they are finalized in regulation.
HAP’s detailed comments elaborate about the need to learn from Stage 2 and build the infrastructure and standards needed to meet today’s meaningful use requirements before finalizing Stage 3 requirements.
In addition, we provide detailed comments on the proposed changes to the structure, objectives, and measures proposed for Stage 3 meaningful use.
Thank you for your consideration of our comments on the proposed rule defining “meaningful use” of EHRs for Stage 3.
If you have any questions, please feel free to contact me, or Martin Ciccocioppo, vice president, research, at (717) 561-5363.
Chief Strategy Officer