AMIA Applauds Flexibilities, Supports 2015 CEHRT Timeline in IPPS Proposed Rule

Tuesday, June 13, 2017

Reductions in required quality measures, flexibilities in EHR reporting periods will benefit hospitals and providers, informatics experts say

In comments submitted to the Centers for Medicare & Medicaid Services (CMS), the nation’s leading clinical informaticians applauded federal officials for proposed reductions in required quality measures, additional reporting period flexibilities, and the proposed certified EHR technology implementation timeline.

CMS announced in April new proposals to reduce the number of required electronic quality measures (eCQMS) for the Hospital IQR Program and the Medicare EHR Incentive Program. Additionally, they proposed reducing the reporting periods for both programs to two self-selected quarters in 2017 and the first three quarters of the year in 2018, if reporting electronically. CMS is also proposing to modify the 2018 EHR reporting period from the full calendar year, to a minimum of any continuous 90-day period for new and returning participants in the Medicare and Medicaid EHR Incentive Programs.

“Generally, AMIA is supportive of the proposed flexibilities afforded to providers for quality reporting and quality payment programs, for example the 90-day EHR Incentive Program reporting period, and reduction of required quality measures,” AMIA said in comments. “Given the need to upgrade to the 2015 Edition Certified EHR Technology, and the changing requirements associated with the program in 2018, we anticipate that providers would benefit from additional time to implement, test and adjust workflows. Likewise, the reduction of eCQMs will better enable hospitals to work towards the goal of more efficient and seamless electronic collection and submission of quality measures.”

However, with regards to the Hospital IQR Program, AMIA did urge CMS to allow the use of any two quarters during 2018 (as is proposed for 2017) in order for hospitals “to reuse data extraction processes in 2018 that were used in 2017 and provide more flexibility and time for hospitals to upgrade and fully implement 2015 CEHRT.” Similarly, AMIA believes that the use of any two quarters should also apply to the 2018 Medicare and Medicaid EHR Incentive Programs, as “they will still need CEHRT to collect applicable data and generate CQM results for attestation.”

AMIA furthermore supports CMS’s proposal to maintain the requirement that EHR technology be certified to the 2015 Edition for CQM reporting, as the current timeline “will encourage continued and sustained resources on IT-enabled care delivery,” AMIA commented. “Improvements to the 2014 Edition, in terms of functionality and capability, need to propagate across the industry, and evidence suggests government-imposed incentives will increase the likelihood this occurs more uniformly.”

“It’s vital that the industry continue its march towards modernization,” said AMIA President and CEO Douglas B. Fridsma, MD, PhD, FACP, FACMI. “APIs and other key aspects of the 2015 Edition will help improve care through improved interoperability and better patient access to their data.”

In response to the proposed rule’s request for information on ways to “reduce burdens on hospitals, physicians, and patients, improve the quality of care, decrease costs, and ensure that patients and their providers and physicians are making the best health care choices possible,” AMIA recommend that CMS:

  • Use data reporting requirements to learn, not simply to grade.
  • Continue to require use of certified EHR technology to participate in incentive programs.
  • Focus on defining clear, expected outcomes, rather than prescriptive process measures.
  • Engage organizations and experts to perform scientifically rigorous, peer-review studies to determine which requirements should be retained in future years.
  • Develop feedback loops that are accurate, timely and meaningful.

“We encourage CMS to view their health IT-related programs as a portfolio of incentives meant to improve care for all Americans,” said AMIA Board Chair and Medical Director of IT at the University of Washington Thomas H. Payne, MD, FACP, FACMI.  “As we head into the eighth year of the EHR Incentive Program, now is the time to evaluate which aspects of the program are working for patients and clinicians, and revisit those that need improvement.”

Click here for AMIA’s full response to CMS proposals.


AMIA, the leading professional association for informatics professionals, is the center of action for 5,400 informatics professionals from more than 65 countries. As the voice of the nation’s top biomedical and health informatics professionals, AMIA and its members play a leading role in assessing the effect of health innovations on health policy, and advancing the field of informatics. AMIA actively supports five domains in informatics: translational bioinformatics, clinical research informatics, clinical informatics, consumer health informatics, and public health informatics.