This week, ASCRS and members of the Alliance of Specialty Medicine sent a letter to CMS Administrator Seema Verma in response to certification requirements for 2018 under the Medicare Electronic Health Record (EHR) Incentive Program included in the 2018 Inpatient Prospective Payment System Proposed Rule. As a reminder, the Meaningful Use program is still in effect for hospitals and Medicaid. In the letter, we explain that providers will face significant challenges with the transition to 2015 Certified EHR Technology (CEHRT) and the Stage 3 measures if they are expected to meet the aggressive deadline of 2018. We highlight that several measures in Stage 3 rely on increased interoperability, which have not been fully developed. Lastly, we note that too few EHR systems are certified to the 2015 Edition, especially for eligible clinicians that provide specialty medical care, to purchase or upgrade by 2018.
We urge CMS to finalize the use of technology certified to the 2014 Edition or the 2015 Edition for the EHR reporting period in 2018. In addition, we express support for allowing providers to use a combination of EHR technologies certified to the 2014 Edition or the 2015 Edition. Lastly, we ask CMS to ensure that all modifications are applied to the Quality Payment Program and other delivery and payment models where CEHRT is required.
We will keep you updated.