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CHIME Issues Comments on EHR Incentive Program
Date:2/27/2010

ul use that is too ambitious, doesn’t take into account the need for flexibility by providers and does not reward incremental progress.

“Without an approach that rewards progress or provides sufficient time, organizations with limited resources will likely have little chance of qualifying for payments, thus widening the ‘digital divide’ in the country,” CHIME’s comments say.

In its recommendations, CHIME wants CMS to give providers until 2017 to adequately achieve all components for EHR implementation; develop an expanded suite of 34 core objectives, some of which can scale over time; use an incremental approach that would deem a provider a meaningful user if it can achieve 25 percent of objectives by 2011, 50 percent by 2013, 75 percent by 2015, and substantially all by 2017.

Contending that the “HIT marketplace does not have the capacity to support the timeframe imposed by the proposed regulations,” CHIME notes that the lack of a certification approach is resulting in industry uncertainty regarding product certification and heightens time pressures that both providers and vendors are facing. CHIME proposes that the final regulations extend the time frame during which Stage 1 meaningful use objectives will be used, and it asks CMS to adopt a “grandfathering provision” under which existing EHR systems that meet meaningful use objectives be accepted as certified for two years.

CHIME’s comments contend that quality reporting requirements in the proposed regulation are unrealistic at the early stages of the incentive program, and it asks for a delay in implementing quality reporting until 2012. “While automated quality reporting is critically important to the meaningful use of electronic health records, no EHR system in use today is able to automatically report the full set of (35) proposed measures.”

CHIME also comments on specific objectives and
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