On March 8, 2010, the American Hospital Association (AHA) submitted comments to CMS on its proposed "meaningful use" rule. "The AHA is very concerned that the high bar for achieving 'meaningful use' and the limited transitions proposed in the NPRM will severely limit hospitals’ ability to access these much-needed resources." The AHA fears "that the ultimate impact of the program actually could be the opposite of the goal of an e-enabled health care system, as those who are furthest behind may well be discouraged by the steep adoption curve."  The AHA proposes an alternative definition of "meaningful use" which includes:

  • Modifying the proposed meaningful use objectives and adding 12 additional objectives;
  • Replacing CMS's proposed adoption year concept with an approach that allows hospitals to satisfy the meaningful use definition if they meet 25 percent of the objectives in 2011 or 2012, and increasing the percentages in future years; 
  • Expanding required levels of use and data sharing requirements over time;
  • Changing many of the measures of meaningful use to decrease the reporting burden;
  • Allowing hospitals to meet the meaningful use objectives by grandfathering currently installed and functioning hospital EHR systems as certified; and
  • Relying on existing quality reporting structures until EHR quality measures and products for quality reporting are ready for broad use.

To read the letter, click here: http://www.aha.org/aha/letter/2010/100308-cl-cms-0033-p.pdf

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