Electronic health record (EHR) vendors and the clinicians they serve need more than a few months to adapt to the Medicare Access and CHIP Reauthorization Act, according to numerous comments submitted to CMS by health IT groups.

That’s not to say all the feedback was negative. Many groups sprinkled their comments with words like “opportunity” and applauded CMS’ efforts to incorporate flexibility into the new payment tracks, the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs).

“We applaud CMS for proposing a set of policies and requirements across the four categories of MIPS and for [APMs] that clearly incorporate stakeholder feedback and lessons learned from the legacies of the Physician Quality Reporting System, Value-Based Modifier, EHR Incentive Program and various alternative payment models,” the American Medical Informatics Association (AMIA) said in its comments. “AMIA believes CMS has an unprecedented opportunity to learn which components of these legacy programs will effectively support our healthcare system in moving toward the triple aim, and we strongly recommend that CMS engage medical informatics expertise more broadly to understand how technology should be leveraged to improve care experience, expense and efficacy."

But AMIA and other groups expressed doubts about the timeline of implementation in the proposed rule. With a final rule not expected until this fall, and reporting then due to begin on Jan. 1, 2017, providers well-versed in meaningful use (MU) requirements would have just a few months to learn a system which, according to AMIA, has a “level of complexity” beyond anything else in Medicare.

To make for a smoother transition, AMIA asked for CMS to issue a “interim final rule,” followed by an additional comment period, and consider only a 90- or 180-day reporting period in 2017 rather than a full year.

Many of the same timeline worries were repeated in a joint letter from the Healthcare Information and Management Systems Society (HIMSS) and the Association of Medical Directors of Information Systems (AMDIS). The groups said extra time to prepare would be especially important for advanced APMs, noting feedback from CMS wouldn’t come until midway through the first reporting year, potentially hurting the ability of clinicians within APMs to make the necessary adjustments to avoid a low performance score.

While generally favoring the move toward “flexibility and customization” in the new technology scoring category, Advancing Care Information, HIMSS and AMDIS did question whether some of these requirements may create duplicative standards on interoperability.

“The attestation requirements that are included in the MACRA NPRM are onerous on providers and far-reaching in their scope. They need to be re-examined in concert with ONC’s recent rulemaking. “In the [rule], CMS notes that it does not want to compromise patient care or be unduly burdensome on eligible clinicians or critical access hospitals, but the language that is included in the attestations on ‘good faith’ comes close to crossing those lines,” the groups wrote. “Closer work with ONC is needed to ensure the strong surveillance of certified health IT products, facilitation of health information exchange and prevention of information blocking.”  

The College of Healthcare Information Management Executives (CHIME) had its own concerns about attestation, urging in its letter that those requirements not be implemented until 2019.