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    February 27, 2017

    Patrick Conway, MD
    Acting Administrator
    Centers for Medicare & Medicaid Services
    U.S. Department of Health and Human Services
    Hubert H. Humphrey Building, Room 445-G
    200 Independence Avenue, SW
    Washington, DC 20201

    Jon White, MD
    Acting National Coordinator
    Office of the National
    Coordinator for Health Information Technology
    Hubert H. Humphrey Building,
    Suite 729D
    200 Independence Avenue, SW
    Washington, DC 20201


    Dear Acting Administrator Conway and Acting National Coordinator White:

    The undersigned organizations are writing to request a deferment from implementing 2015 Edition certified electronic health record technology (CEHRT) until such technology is widely available, and, in no event, sooner than January 2019. The physician community thanks the Centers for Medicare & Medicaid Services (CMS) for permitting the use of both 2014 and 2015 Editions in the Quality Payment (QPP) and the Meaningful Use (MU) programs in 2017. These programs, however, require the use of 2015 Edition technology starting in 2018. For reasons described in this letter, we believe that the technology will not be readily available to physicians across a wide variety of specialties and that the use of 2015 Edition CEHRT should remain voluntary.

    Mandating 2015 Edition CEHRT by 2018 Jeopardizes Success in the QPP and MU

    While over 16 months have passed since the Office of the National Coordinator for Health Information Technology (ONC) released the final 2015 Edition requirements, few vendors have fully upgraded their systems—only 54 of the over 3,700 products are currently certified and posted on the Certified Health IT Product List (CHPL). Importantly, the vast majority of the certified 2015 Edition products are from a small number of vendors. Requiring physicians to upgrade to 2015 Edition technology by 2018 limits choice by forcing physicians to select a system from approximately one percent of existing products. In addition, physicians may be driven to switch vendors and utilize a system that is not suitable for their specialty or patient population due to this tight timeline. This is not only contrary to the purpose of an electronic health record (EHR)—a tool to help physicians respond to patient care needs—but also jeopardizes a physician’s chance of success in the QPP and MU. Physicians should not be subject to financial penalties under the QPP and MU because vendors have not certified their 2015 Edition products in a timely manner.

    A Rush to Certify Products Will Result in Broad Hardship Exemptions

    We urge CMS to recall that the switch to 2014 Edition CEHRT created similar challenges and resulted in a large backlog of products. This eventually required CMS to create a hardship exemption for technology delays that was announced late into the program year—furthering confusion and uncertainty in the MU program. Given that only 54 products are currently certified to the 2015 Edition, there will likely be a similar rush to certify hundreds, if not thousands, of additional products in 2017 and substantial implementation delays. To avoid repeating these problems, CMS should adjust its timeframe for the required use of 2015 Edition technology.

    Hasty Deployment of CEHRT is Counterproductive and Threatens Patient Safety

    While we acknowledge that the 2015 Edition contains functionality that may improve data access, integration of patient generated health data, and document sharing, initial implementation and utilization of these new tools may prove complex. To effectively and safely use these new features, health systems must develop internal guidance, principles, and practices to ensure they improve, not detract from, patient care. We are concerned that requiring the use of 2015 Edition CEHRT by 2018 will result in rushed upgrades, installations, a lack of user training, and an overall disruption to physicians’ practices. As such, physicians should identify their own 2015 Edition-rollout timeline independent of federal regulation.

    We are also concerned that, in addition to the significant changes that the QPP will bring to a physician’s practice in 2017, the current CEHRT timeline ignores the needs of practices with few technology resources. Many small and solo practices have historically learned about implementation from early adopters but will not have time to do this under the current time constraints. The new Edition also includes new measures that will likely be challenging and demanding for practices. To assist these practices, CMS should continue to allow the use of both 2014 and 2015 Editions and permit participants to meet modified Stage 2 MU and Advancing Care Information (ACI) measures.

    2015 Edition CEHRT Should Incorporate Improvements to EHR Certification

    Congress outlined a number of needed EHR certification improvements with passage of the 21st Century Cures Act. Specifically, the law directs the Secretary of Health and Human Services (HHS) to develop a strategy to reduce EHR regulatory and administrative burden and requires, as a condition of certification and maintenance of certification, new requirements for developers. These requirements address many of our long-standing concerns with EHRs, including prohibiting vendor data blocking; improving the usability, interoperability, and security of EHRs; and testing CEHRT in real-world settings. We view these as necessary protections that will shed new light on how EHRs perform in our members’ practices. While we applaud Congress on the passage of these provisions, and are committed to working with HHS to implement them, we are concerned these protections will not be in place before vendors develop, test, and certify 2015 Edition products. It is clear that Congress intended for physicians to be better equipped to make EHR purchasing or upgrading decisions; yet, we fear without deferring the 2015 Edition requirements, most EHRs will not conform to these new and vital certification improvements.

    Conclusion

    Thank you for your consideration of how we can safely and effectively move to 2015 CEHRT. Improving technology, while reducing administrative burden and costs are key concerns across industry stakeholders. We are eager to continue working with you to further our mutual goals.

    Sincerely,
    American Medical Association
    Advocacy Council of the American College of Allergy, Asthma, & Immunology
    American Academy of Allergy, Asthma & Immunology
    American Academy of Dermatology
    Association American Academy of Emergency Medicine
    American Academy of Family Physicians
    American Academy of Home Care Medicine
    American Academy of Neurology
    American Academy of Orthopaedic Surgeons
    American Academy of Otolaryngic Allergy Inc
    American Academy of Otolaryngology—Head and Neck Surgery
    American Academy of Physical Medicine and Rehabilitation
    American Association of Clinical Endocrinologists
    American Association of Hip and Knee Surgeons
    American Association of Neurological Surgeons
    American Association of Neuromuscular & Electrodiagnostic Medicine
    American College of Allergy, Asthma and Immunology
    American College of Cardiology
    American College of Emergency
    American College of Gastroenterology
    American College of Mohs Surgery
    American College of Osteopathic Internists
    American College of Phlebology
    American College of Physicians
    American College of Radiation Oncology
    American College of Radiology
    American College of Rheumatology
    American College of Surgeons
    American Congress of Obstetricians and Gynecologists
    American Gastroenterological Association
    American Geriatrics Society
    American Osteopathic Association
    American Psychiatric Association
    American Rhinologic Society
    American Society for Clinical Pathology
    American Society for Dermatologic Surgery
    Association American Society for Gastrointestinal Endoscopy
    American Society for Radiation Oncology
    American Society of Anesthesiologists
    American Society of Cataract and Refractive Surgery
    American Society of Clinical Oncology
    American Society of Dermatopathology
    American Society of Hematology
    American Society of Neuroradiology
    American Society of Nuclear Cardiology
    American Society of Plastic Surgeons
    American Society of Retina Specialists
    American Academy of Ophthalmology
    Association of American Medical Colleges
    Congress of Neurological Surgeons
    Heart Rhythm Society
    Infectious Diseases Society of America
    International Society for the Advancement of Spine Surgery
    Medical Group Management Association
    North American Neuro-Ophthalmology Society
    North American Spine Society Renal Physicians
    Association Society for Vascular Surgery
    Society of Critical Care Medicine
    Society of Nuclear Medicine and Molecular Imaging
    The Society of Thoracic Surgeons
    Medical Association of the State of Alabama
    Arkansas Medical Society
    California Medical Association
    Connecticut State Medical Society
    Medical Society of Delaware
    Medical Society of the District of Columbia
    Florida Medical Association Inc
    Medical Association of Georgia
    Hawaii Medical Association
    Idaho Medical Association
    Illinois State Medical Society
    Iowa Medical Society
    Kansas Medical Society
    Kentucky Medical Association
    Louisiana State Medical Society
    Maine Medical Association MedChi
    The Maryland State Medical Society Massachusetts
    Medical Society Michigan State
    Medical Society Minnesota Medical Association
    Mississippi State Medical Association
    Missouri State Medical Association
    Montana Medical Association
    Nebraska Medical Association
    Nevada State Medical Association
    New Hampshire Medical Society
    Medical Society of New Jersey
    New Mexico Medical Society
    Medical Society of the State of New York
    North Carolina Medical Society
    North Dakota Medical Association
    Ohio State Medical Association
    Oklahoma State Medical Association
    Oregon Medical Association
    Pennsylvania Medical Society
    Rhode Island Medical Society
    South Carolina Medical Association
    South Dakota State Medical Association
    Tennessee Medical Association
    Texas Medical Association
    Vermont Medical Society
    Washington State Medical Association
    Wisconsin Medical Society
    Wyoming Medical Society

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