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EHR Certification Process

June 3, 2019
The AAAAI recently reiterated its support for a robust network that allows both patients and providers to effortlessly exchange health information,  technology essential to improving the lives of patients with A/I conditions. Read the letter.

Congress extends hardship exception for Meaningful Use Stage II; where are you in this conversation?
In order to avoid a penalty under the Meaningful Use (MU) program, eligible professionals must attest that they met the Stage 2 requirements for a period of 90 consecutive days during calendar year 2015. However, CMS did not publish the final rule outlining modifications for Stage 2 of MU until October 16, 2015; leaving fewer than the 90 required days for reporting remained in the calendar year in which to meet the modified requirements.

Given the late release of the final rule, the AAAAI joined other physician organizations to advocate for Congressional intervention to simplify the hardship exception process for eligible professionals. As a result, moments before adjournment for the year, the House of Representatives and U.S. Senate passed the "Patient Access and Medicare Protection Act," which will allow CMS to approve hardship exception applications in "batches" through March 15, 2016. Therefore, eligible professionals who apply for a hardship exception by March 15, 2016 will automatically receive a hardship exemption. Applications for the hardship exception will be available in early 2016.

Those who apply for a hardship exception after March 15, 2016, must apply for a hardship exception under CMS' "extreme and uncontrollable circumstances" category. These hardship exception applications will be reviewed on a case-by-case basis, as required by law. Applications will be due no later than July 1, 2016.

An approved hardship exception for 2015 will exempt eligible professionals from the MU payment adjustment in 2017.

Meanwhile, this is a good time to be planning for Meaningful Use participation in 2016. The AAAAI continues to develop its Quality Clinical Data Registry (the "AAAAI QCDR") to offer specialty registry reporting for Meaningful Use Stage II compliance as well as for the PQRS program. More information about the QCDR, including a webinar on what the QCDR can do for you, is available here.

Finally, the AAAAI wants to know how health information technology is working in your practice. As the recent Congressional action described above shows, there is considerable ongoing discussion at the national level regarding the challenges of electronic health record implementation in physician practices. The AAAAI is a member of the Healthcare Information Management Systems Society (HIMSS), and we have partnered with them to invite you to participate in a survey about the value and use of healthcare information technology in practice.

AAAAI Weighs in on Health IT Certification Criteria and Meaningful Use Stage 3
Members of the AAAAI Health Informatics, Technology & Education Committee worked with staff from the AAAAI and Hart Health Strategies to respond to two recent areas of proposed regulation which are of interest to the A/I specialty. In response to the 2015 Edition Health Information Technology (Health IT) Certification Criteria, 2015 Edition Base Electronic Health Record (EHR) Definition, and ONC Health IT Certification Program Modifications, comments were submitted to address appropriate documentation of medication allergies and pharmacogenetic variants. Comments submitted regarding Stage 3 of the Medicare and Medicaid EHR Incentive Program and associated Meaningful Use criteria addressed a number of issues and challenges A/I physicians face in participating in Meaningful Use.

View the AAAAI comments on Health IT Certification Criteria.
View the AAAAI comments on Meaningful Use Stage 3.

CMS released a proposed rule that aims to ease the reporting burden of the Meaningful Use program for 2015 through 2017, as well as make it more meaningful to providers. The rule proposes to reduce the overall number of objectives and to extend the 90-day reporting period to 2015.

Please note that this rule is separate from, but meant to align with, the recently released proposed rule outlining requirements for Stage 3 Meaningful Use.

In coalition with the American Medical Association and others, the AAAAI recently expressed concerns among physicians regarding the electronic health records (EHR) certification process, and outlined several recommendations for improvements to the Office of the National Coordinator for Health Information Technology. EHR system issues raised included: performance, usability, interoperability and lack of patient safety measures. To improve the systems before certification, the AAAAI, with others, made recommendations to decouple the EHR certification process from the Meaningful Use program, reconsider alternative software testing methods, and to seek further stakeholder feedback with other measures. Review the letter signed in coalition with 35 other associations.

Following the joint response including AMA and a number of other medical societies, Dr. Patrick Conway of CMS announced on January 29 that CMS is considering several changes to the Meaning Use requirements.

The AAAAI recently signed on to a letter to CMS with the AMA and a number of other organizations expressing ongoing concerns related to the ICD-10 implementation slated for October 1, 2015. View the letter.