The American Hospital Association is urging the Office of the National Coordinator to relax its rules on meaningful use so EHRs do not have to be certified against all 24 criteria, arguing that the requirement is inconsistent since hospitals are required to report on 19 measures.
"The requirement that hospitals have EHRs certified against all 24 measures of meaningful use is inconsistent with the CMS final rule on meaningful use, which states that a hospital may 'defer' up to five objectives of meaningful use in 2011 and 2012," AHA President and CEO Rich Umbdenstock wrote in a Nov. 30 letter to Health and Human Services Secretary Kathleen Sebelius. "The AHA asks that the department take a consistent approach to meaningful use that requires hospitals to have EHR technology certified against only those 19 objectives they will use to demonstrate meaningful use."
The ONC falls under the umbrella of HHS.
"The AHA is concerned that ONC's interpretation will require hospitals to have technology related to meaningful use objectives for which CMS has provided specific exclusions in its final rule," Umbdenstock wrote. "We do not understand why CMS would provide an exception in these circumstances, but still require hospitals to pay for the acquisition and installation of the technical capacity to meet the objectives. In Section 495.6 of the final rule, CMS outlined exclusions for seven objectives, if hospitals meet the related exclusion criteria."
The letter listed potential impact on hospitals if the rule were not reinterpreted:
- Hospitals will have to commit additional, unplanned financial resources to purchase additional functionality, which may require board approval for additional borrowing.
- Hospitals will be delayed in the achievement of meaningful use because they will have to negotiate contracts with their vendors for additional functionality and wait for the vendor to schedule implementation.
- Hospitals will need to revise and accelerate implementation plans to add additional, unplanned modules, increasing the workload of already stressed health IT implementation teams.
- Hospitals will be forced to purchase relatively new and untested technology that has not yet been widely used in the market. This means that all hospitals seeking to become meaningful users will have to buy and implement first generation technology that may not be effective or best meet their needs. Examples include technology to provide biosurveillance data to public health agencies through the EHR or to identify patient- specific education resources through the EHR.
- Hospitals will be locked into the technology currently on the market, limiting their ability to benefit from innovative solutions that arise in the coming years. It also could limit the number of new vendors offering fresh approaches to meeting specific objectives, such as providing web-based access to patient-specific health information in multiple languages or real-time interfaces to multiple drug formularies.