CHIME Submits Meaningful Use 2 Comments
CHIME Calls for Time Flexibility, Certification of All Clinical Quality Measures
ANN ARBOR, MI, APRIL 30, 2012 – Today, the College of Healthcare Information Management Executives
(CHIME) submitted its comments on the proposed rules for Stage 2 Meaningful Use, calling for more
time to allow healthcare organizations to better prepare.
Comments filed with both the Centers for Medicare & Medicaid Services (CMS) and Office of the National
Coordinator for Health IT (ONC) identified concerns related to the proposed Stage 2 EHR reporting period
as well as CMS’ varying approach to clinical quality measures (CQMs). CHIME also made recommendations
on all 42 proposed objectives for Eligible Professionals, Eligible Hospitals and Critical Access Hospitals.
CHIME recommended that CMS allow EPs, EHs and CAHs to demonstrate Meaningful Use during a continuous 90-day
EHR reporting period for their first payment year in Stage 2, mimicking the approach used in Stage 1.
“To allow adequate time for application development, provider adoption and testing, CMS should follow the
precedent set in Stage 1,” CHIME said. “And similar to Stage 1, the EHR reporting period would be any
continuous 90-day period within the first payment year of Stage 2 and a 365-day reporting period for all
subsequent payment years within Stage 2.”
“We felt the approach taken in Stage 1 gave providers much-needed time to make sure the correct fields were
populating and accurate Meaningful Use reports were being produced – we think a similar approach is needed
for Stage 2 and beyond,” said Pam McNutt senior vice president and chief information officer at Dallas-based
Methodist Health System.
“While we appreciate the delay of Stage 2 to Fiscal Year 2014, that decision was necessary, given that no
one would be in a position to meet Stage 2 requirements beginning Oct. 1, 2012,” said McNutt, a member of
CHIME’s Policy Steering Committee. “By giving providers flexibility through a 90-day reporting window, CMS
can ensure that more Stage 1 Meaningful Users will become Stage 2 Meaningful Users.”
In both letters, to CMS and ONC, CHIME commented on the challenges involved with clinical quality measures.
“The accurate reporting of quality measures is one of the most daunting challenges faced by providers today,”
CHIME said. “Through our experiences with Stage 1, we found that although EHR products were able to automatically
produce CQM reports, the data was inaccurate and largely incomparable across different providers.”
As part of Base EHR certification, CHIME urged ONC to require certification of EHR products to all CQMs needed to
meet Meaningful Use in each setting. CHIME wrote that “certification should include all CQMs for associated settings.
And in order to minimize the costs of development and implementation, we recommend that ONC work with CMS to limit the
total number of CQMs associated with each setting.”
“Quality measures are a vital component to increasing care efficiency, decreasing disparities and lowering costs,”
said Elizabeth Johnson, vice president of applied clinical informatics at Tenet Healthcare, and a member of CHIME’s
Policy Steering Committee. “It is clear that ONC recognizes the value of quality measures, but the state of quality
measurement needs to mature. HHS has been working to harmonize CQMs across its various reporting programs; however,
more must be done to make the quality metrics consistent and meaningful.”
CHIME’s comments include suggestions on all 42 objectives and measures for both ambulatory and inpatient settings of care.
While CHIME supported nearly every measure meant to meet each objective, member CIOs were concerned with the lack and
types of menu options for EPs, EHs and CAHs. “The menu set for both EPs and hospitals is quite small in relation to the
minimum number that would need to be met, thereby providing relatively few options for EPs and hospitals,” the comment
letter said. “A number of the proposed menu set objectives and measures also would have non-trivial cost implications
for EPs and hospitals.” CHIME urged CMS to carefully assess both the number and feasibility of menu options for the
average physician practice or the average hospital in finalizing its rule for Stage 2.
CHIME’s comments to CMS can be found here.
For CHIME’s letter to ONC, visit here.
The College of Healthcare Information Management Executives (CHIME) is an executive organization dedicated to serving
CIOs and other senior healthcare IT leaders. With more than 1,400 members and over 87 healthcare IT vendors and professional
services firms, CHIME provides a highly interactive, trusted environment enabling senior professional and industry leaders to
collaborate; exchange best practices; address professional development needs; and advocate the effective use of information
management to improve the health and healthcare in the communities they serve. For more information, please visit www.cio-chime.org.
Updated: 4/30/2012 3:31:06 PM