In comments submitted to the Office of the National Coordinator for Health Information Technology (ONC) on Jan. 14, the America Medical Association (AMA) made its case for thorough evaluation of the first two stages of the federal meaningful use incentive program before proceeding to Stage 3.
“The AMA shares the administration’s goal of widespread EHR adoption and use, but we again stress our continuing concern that the meaningful use program is moving forward without a comprehensive evaluation of previous stages to resolve existing problems,” said AMA Board Chair Steven J. Stack, MD, in a prepared statement.
“A full evaluation of past stages and more flexible program requirements will help physicians in different specialties and practice arrangements successfully adopt and use EHRs," Stack added.
In its letter to National Coordinator Farzad Mostashari, MD, the AMA offered five concerns and recommendations to improve the meaningful use program.
First, the association questioned the lack of an external, independent review process, which it insisted was necessary to improve and inform the future of meaningful use. The Centers for Medicare & Medicaid Services (CMS) and ONC "have not evaluated the meaningful use program," wrote AMA's executive vice president and CEO James Madara, MD. "Given the concerns raised with the current program, an external, independent evaluation is necessary to improve and inform the future of the program."
Moreover, he wrote, "We believe that it is a serious mistake to keep adding stages and requirements to the meaningful use program without evaluating Stage 1 of the program. In addition, an evaluation should occur between each stage of the meaningful use program and prior to finalizing the requirements for the next stage."
AMA also argued that a 100 percent pass rate was the wrong approach: "The current and future meaningful use requirements are problematic, given that failing to meet just one measure by one percent would make a physician ineligible for incentives and subject to financial penalties. The measures for use of EHRs should be made reasonable and achievable and still have a meaningful impact."
Relatedly, the association has expressed qualms about ONC's "one-size-fits-all" approach, calling for more flexible program requirements that take different practice patterns and specialties into consideration.
"Under the current program, every physician regardless of their specialty must meet the same measures (i.e., core measures), and there are few exceptions," the AMA's letter stated. "The program requirements should be appropriately flexible and better structured to accommodate various practice patterns and specialties. Also, additional resources and time to develop and test e-specified electronic measures focused on outcomes must be allotted to ensure successful implementation of the meaningful use program."
AMA also called for the EHR certification process to address physician's concerns about design and ease of use.
"Usability standards being included in the certification criteria will be critical for ensuring that physicians invest their resources in EHR, CPOE, as well as other health IT products that work for them," wrote Madara. Physicians are worried about the viability of the systems in which they've invested, and are "concerned about potential liabilities from EHR system design and software flaws as well as lack of interoperability among EHR systems that could result in incomplete or missing information, which may lead to errors in patient diagnosis and treatment (e.g., patient matching)."
Finally, the AMA called for progress on breaking down infrastructure barriers that are hindering information exchange. "Improving the health IT infrastructure to allow physicians to readily and securely exchange patient data with other health care providers should be made a top priority and take precedence over the development of future stages of the meaningful use program."
While meaningful use has helped to jumpstart EHR adoption, "We are still in the early stage of progress due to technological, financial, operational and regulatory challenges," wrote Madara. "These challenges must be overcome in order to increase physician participation rates and maximize the benefits of this technology for our nation’s health care delivery system."
Read the full AMA letter here.