Premier Health Alliance, which represents more than 2,600 hospital members:
Premier supports the CMS decision to extend Stage 1 MU, but wants CMS to publish a final rule specifying Stage 2 requirements by August 2012 warning that failure to do so will "seriously compromise the ability of the healthcare community to meet Stage 2 requirements beginning in 2014." If the August deadline can't be met, Premier recommends that Stage 1 be continued for an additional year, and that Stage 2 begin in 2015.
Premier likes the proposal that hospitals report clinical quality measures from a menu of options but asks that the CQM be reduced to 15 instead of the proposed 24. "Our alliance members have encountered significant difficulties in complying with the 15-measure requirement in Stage 1, in some cases due to problems with the performance of certified EHR technology, and we believe it would be more prudent to retain a 15-measure reporting requirement for Stage 2 rather than overreach."
It would like to see timeline for online access be two business days rather than 36 hours after discharge. "A measure based on full days would be simpler than one based on hours post-discharge, since discharges can occur throughout the day, making for a potential compliance nightmare."