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CHIME Voices Concerns About Proposed ARRA Regulations
Date:1/8/2010

visions favors the phased approach used to measure the meaningful use of electronic health records. Through the phased approach, first-year meaningful use criteria will apply to hospitals whenever they are eligible. However, the current schedule places pressure on hospitals that delay in implementing electronic health records, because by 2015, all hospitals and eligible providers would need to meet Stage 3 criteria to avoid payment penalties.

“Adequate time to understand the impact of these new systems and to implement them, are some of my secondary concerns,” said David Muntz, Senior Vice President and CIO of Baylor Health Care System. “My primary concern is the time and effort required to achieve successful organizational change management.”

To qualify for the incentive payments in either Medicare or Medicaid, eligible providers and hospitals must use certified EHRs to meet specific objectives and report specific HIT functionality measures to the Centers for Medicare & Medicaid Services. Additional quality measures also will need to be submitted, and as a whole, reporting requirements will be burdensome; many of the measures will require organizations to gather information that spans both electronic and paper-based systems, such as the percentage of orders entered through CPOE systems.

Initial reporting will be done through attestation to CMS, but that will still require hospitals to provide data on each of the HIT functionality measures.

Quality reporting provisions of the regulation also will require hospitals to develop reporting capabilities, since only nine of the 35 quality measures being proposed in the regulations currently are in use in the Medicare pay-for-reporting program.

For physicians, the use of Physician Quality Reporting Initiative indicators for reporting quality data will be a major challenge, CHIME believes. The proposed regulations indicate that medical groups that quali
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