- In a letter to President-elect Donald Trump, the American Hospital Association has called for a cancellation of Stage 3 Meaningful Use for hospitals among numerous other recommendations focused on topics ranging from reducing regulatory to advancing health system transformation.
“The regulatory burden faced by hospitals is substantial and unsustainable,” writes AHA President & CEO Richard J. Pollack. “We urge your Administration to modify or eliminate duplicative, excessive, antiquated and contradictory provider regulations. Reducing the administrative complexity of health care would save billions of dollars annually and would allow providers to spend more time on patients, not paperwork.”
Atop that list of regulatory burden reductions is Stage 3 Meaningful Use, which with the final rulemaking for the Quality Payment Program under MACRA implementation applies to eligible hospitals alone.
“Cancel Stage 3 of the meaningful use program so that hospitals will not be forced to spend large sums of money upgrading their electronic health records (EHRs) solely for the purpose of meeting regulatory requirements,” the letter states.
The organization has a long history of opposing the approach taken by the Centers for Medicare & Medicaid Services to build on the adoption of certified EHR technology under meaningful use. As evidenced by this letter, AHA is ready and willing to move beyond the program.
On the subject of EHR technology and other health IT systems, the AHA letter makes clear an organizational focus on EHR interoperability and integration in lieu of a continued focus on EHR adoption and use in two separate recommendations (one explicit and the other implicit).
Also as part of recommendations for reducing regulatory burden, AHA calls for the creation of “exception safe harbors and waivers under the Anti-kickback statute to protect clinical integration arrangements and revise the ‘Stark law’ to protect arrangements that meet the Anti-kickback safe harbor so that physicians and hospitals can work together to improve care.”
While the recommendation most directly refers to accountable and value-based care arrangements between hospitals and physicians that could violate these regulations, safe harbors have allows for EHR donations that allow hospital, a health system, or an accountable care organization to offset the cost of EHR technology for physician practices.
Under the category of recommendations for continued improvements to care quality and patient safety, AHA voices a “need to ensure we have the workforce and health IT infrastructure to best support care delivery.”
“Advance health IT by supporting the adoption of interoperable EHRs, promoting a more consistent use of IT standards and providing improved testing, certification, and transparency about vendor products,” the specific recommendation reads.
Along similar lines, the AHA letter includes a recommendation to help hospital-based physicians participating in quality reporting programs as part of MACRA implementation under the same category.
“Develop a performance reporting option that allows hospital-aligned physicians to fulfill the Medicare Access and CHIP Reauthorization Act (MACRA) quality reporting requirements based on hospital measures,” Pollack advises.
Also on the subject of MACRA, AHA includes a recommendation for assisting participants in the Alternative Payment Models (APMs) component of the Quality Payment Program.
“Expand the definition of advanced alternative payment models to allow more clinicians who partner with hospitals on new models to achieve payment incentives under MACRA,” writes Pollack.
Elsewhere on the subjects of health IT infrastructure, AHA seeks resolution to regulations restricting the wider use of telehealth services:
“Promote the use of telehealth, remote patient monitoring and similar technologies by removing barriers to their use and payment,” reads one recommendation for advancing health system transformation and innovation.
“Waive the skilled nursing facility three-day stay rule, telehealth restrictions and prospective beneficiary assignment from all ACO models,” states another.
While the call to cancel Stage 3 Meaningful Use is one of nearly 30 total recommendations, it is the first and one very much in line with industry-wide calls for a focus on making current health IT infrastructure interoperable to support care delivery transformation rather than on demonstrating certain uses of EHR technology and health IT systems.