ASA Comments on CMS Rule Regarding 2014 Edition CEHRT

On July 21, the American Society of Anesthesiologists (ASA) offered general support to a CMS proposed rule that modifies Certified Electronic Health Record Technology (CEHRT) requirements for 2014 and requested a review of how physicians, including anesthesiologists, report electronic Clinical Quality Measures (CQMs). The ASA comment letter also reiterated the importance of the Hardship Exemption for anesthesiologists. The hardship exemption allows anesthesiologists to avoid the EHR program payment adjustment.

The proposed rule, applicable to practitioners participating the EHR Incentive Program, would allow providers who could not fully implement 2014 Edition CEHRT (because of delays in 2014 Edition availability) to continue to use 2011 Edition CEHRT or a combination of the 2011 and 2014 Editions for Stage 1 or Stage 2 meaningful use.  The proposed rule is valid for 2014 only. CMS has provided a tool for eligible professionals participating in the program to understand how the rule, if finalized, might affect their participation.

ASA also supported the provision for delaying meaningful use Stage 3 to 2017. In particular, ASA appreciated the intent of CMS and the Office of the National Coordinator for Health Information Technology (ONC) to analyze Stage 2 data in preparation for making Stage 3 criteria decisions. The proposed rule for Stage 3 meaningful use has not been released.

ASA also requested a critical evaluation of CQMs that physicians, including anesthesiologists, may report. CMS has sought opportunities in the past to align CQM reporting across both the EHR and Physician Quality Reporting System (PQRS) programs. However, since most CQMs reflect primary care practice and chronic care management, the streamlining of such measures often fails to address the underlying challenge for anesthesiologists to report specialty-specific measures. ASA asked CMS to explore additional pathways for implementing specialty-specific CQMs across both EHR and PQRS programs.

For more information, please visit the ASA webpage on EHRs or contact the ASA Department of Quality and Regulatory Affairs (QRA) at (202) 289-2222 or via e-mail at [email protected].