A clash of schedules is emerging, one that worries the advocacy professionals at the Ann Arbor, Mich.-based College of Healthcare Information Management Executives (CHIME). On Monday morning, Mari Savickis, vice president, federal affairs, and Leslie Kriegstein, vice president, congressional affairs, for the association, sent CHIME members a notice regarding members’ opportunity to share with the Centers for Medicare & Medicaid Services (CMS) their concerns over the current situation with the CEHRT (Certified Electronic Health Record Technology) program, and the very significant possibility that hospital organizations could be penalized for not using EHRs that have been certified as of the 2015 program requirements, even as EHR vendors have not yet completed their certifications.
Here’s the background: as the CMS website notes, “In order to capture and share patient data efficiently, providers need an EHR that stores data in a structured format. Structured data allows patient information to be easily retrieved and transferred, and allows the provider to use the EHR in ways that can aid patient care. CMS and the Office of the National Coordinator for Health Information Technology (ONC) have established standards and other criteria for structured data that EHRs must meet in order to qualify for use in the Medicare and Medicaid EHR Incentive Programs. To get an incentive payment, you must use an EHR that is certified specifically for the EHR Incentive Programs. CEHRT gives assurance to purchasers and other users that an EHR system or module offers the necessary technological capability, functionality, and security to help them meet the meaningful use criteria. Certification also helps providers and patients be confident that the electronic health IT products and systems they use are secure, can maintain data confidentially, and can work with other systems to share information.”
As Savickis and Kriegstein noted in their alert to CHIME members, “We are halfway through 2017 and most vendors still are not certified for 2015 CEHRT, raising concerns among members that their success at Meaningful Use, MIPS and a host of other programs CMS has hitched to this wagon will be jeopardized. Act today to help us convince CMS that another year using 2014 Edition CEHRT will give the provider and vendor community more time to prepare.”
Their notice also provides a link (which can be clicked here), for CHIME members to be able to send comments to CMS officials regarding this timeline challenge.
Shortly after their alert had been sent to members, Savickis and Kriegstein spoke with Healthcare Informatics Editor-in-Chief Mark Hagland regarding their alert. Below are excerpts from that interview.
When you look at the timelines involved around CEHRT, what are the concerns that prompted your alert to CHIME members this morning?
Mari Savickis: We have a situation where our members are telling us that they don’t have their products delivered. If you don’t have your products delivered, you can’t meet meaningful use, and you’re in for a big penalty, and that doesn’t even touch on other issues for them, around MACRA [the Medicare Access and CHIP Reauthorization Act of 2015], for example.. So if products aren’t delivered on time, you’re risking provider success. So we’re urging providers to make comments to CMS by tomorrow. It’s not ‘new-new’; we’re just reiterating things we’ve said before—but in a more time-sensitive context.
And how might all of this play out in the near future?
Kriegstein: I think we will have to wait and see, esp. with the MACRA rules coming, to see whether 2016 CEHRT will remain the CEHRT of the land or not.
Savickis I would have thought that [the release of the] IPPS [Inpatient Prospective Payment System rule] would be the bellwether [for how and what CMS would require], but because IPPS was almost fully baked already, I would consider the MIPS rule as most significant here [the release of the rule related to the Merit-based Incentive Payment Program under the MACRA law].
And when will the MIPS rule come out?
Savickis: Probably in the next two weeks, but we’ve heard that being said before.
