AOA lobbies for changes in EHR Incentive Programs

June 23, 2015
Member feedback informed comments to CMS.

Armed with member feedback, the AOA recently issued comments to the Centers for Medicare & Medicaid Services (CMS) on how to improve the EHR Incentive Programs for doctors of optometry.

The AOA has long warned CMS that the meaningful use standards were ill-advised.

Two letters sent to CMS Acting Administrator Andrew M. Slavitt on May 29 and June 15 reflect AOA members' concerns that various regulatory requirements of the EHR Incentive Programs have distracted from the programs' true aim—to increase the number of providers using EHRs to improve patient care.

As stated in the June 15 letter: "Given the serious problems encountered by physicians related to certification and Stage 2 implementation in 2014, program changes are critically needed in 2015 and going forward. The AOA has long warned CMS that the meaningful use standards were ill-advised, placing far too many demands on doctors and software developers."

The AOA parsed CMS' proposed rules on modifications to meaningful use in 2015-2017 as well as the criteria for Stage 3, and offered specific responses to both:

2015-2017 Changes

  • EHR reporting periods

    AOA supports a 90-day reporting period in 2015-2016, and also urges CMS continue this into 2017-2018 as the proposal to eliminate the 90-day reporting period in 2017 seems out of step with previous CMS adjustments to the program.
  • Clinical quality measurement

    AOA supports the additional flexibility that CMS has proposed to allow physicians to report on Clinical Quality Measures (CQMs) for any 90-day period in 2015, even if it is different from the 90-day period chosen for attestation for the meaningful use objectives.
  • Payment adjustments and hardship exemptions

    AOA is concerned with the CMS statement that due to the delay in the opening of the attestation period to Jan. 1, 2016, doctors new to the program would experience payment penalties on claims in 2016 that are submitted prior to the doctor’s attestation. AOA suggests it would be preferable to delay implementation of payment penalties until after the attestation period closes.
  • Patient electronic access

    AOA supports the CMS proposal to modify the measure previously requiring 5% of patients to view, download or transmit to third-party health information.
  • Patient engagement

    AOA urges finalization of the CMS proposal to modify the secure electronic messaging measure to allow doctors to attest to the capability of EHR for sending and receiving electronic messages, and AOA agrees that CMS should allow for greater flexibility in meeting the patient engagement measures.

Criteria for meaningful use Stage 3

  • Reporting periods

    AOA urges CMS not to eliminate the 90-day reporting period for all physicians—except Medicaid providers in their first year of demonstrating meaningful use—starting in 2017. The number of changes CMS proposed for the next two years make an abbreviated reporting period necessary for doctors trying to meet future program requirements.
  • Definition of meaningful use

    AOA strongly opposes the CMS proposal requiring all physicians—regardless of prior participation in the EHR Incentive Programs—to meet Stage 3 requirements by 2019, and AOA encourages more flexibility in allowing doctors in 2017 to remain in Stage 2 or move to Stage 3.
  • Electronic vs. paper-based objectives and measures

    AOA opposes the CMS proposal to discontinue use of non-electronic formats to meet certain measures under Stage 3, namely the use of patient-specific education resources as it seems the use of a certain media type is prioritized over ensuring a patient gets the clinically relevant material they need.
  • Public health and clinical data reporting

    AOA is concerned that the public health objectives will be difficult for many physicians to achieve, and AOA encourages CMS to reduce the number of public health or clinical data registry measures required to be reported. AOA urges implementing more exclusions for these measures to allow doctors to exclude measures if their EHR cannot automatically report to these registries.
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