Proposed meaningful
use stage 3 Criticized as hasty and too strict
Rigid requirements to meet electronic health
record measures will trip up physicians attempting to stop upcoming penalties,
warn the AMA and others in organized medicine.
Washington
Criteria floated for the final stage of the federal electronic health record
incentive program would be extremely difficult for physicians to meet, causing
those using the systems at their practices to fall short of requirements and
exposing them to lower Medicare payments, organized medicine groups say.
A
health information technology committee under the Dept. of Health and Human
Services has drafted preliminary recommendations for stage 3 of the EHR
meaningful use program. The committee wants the program to support new care
models, apply broadly to specialties and reflect technologies that are becoming
available. But physician organizations, including the American Medical
Association, are urging federal officials to review and improve the first two
stages of paperless record standards before jumping ahead too hastily.
“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 Steven J. Stack, MD, chair of the AMA Board of
Trustees. “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.”
The
earliest physicians will see stage 3 is 2016. Stage 2 won’t begin until 2014
for the earliest adopters, and physicians who have not yet adopted EHRs will
spend two years under stage 1 criteria before they start progressing to the
next stages.
Physicians
can earn up to $44,000 in Medicare bonuses or $63,750 from Medicaid. Incentives
taper off over time, with Medicare and Medicaid bonuses ending in 2016 and
2021, respectively. Those not achieving meaningful use by October 2014 stand to
be assessed Medicare payment penalties beginning in 2015.
The
committee had sought comments from stakeholders on its recommendations to
retire several meaningful use measures and strengthen other requirements in
stage 3. Even though the meaningful use program has spurred adoption of EHRs
and led to more than 125,000 physicians receiving bonuses, the AMA and others
have identified several areas that they say need improvement before the program
can move forward.
“A number of the proposed
stage 3 measures necessitate significant increases in clinical documentation,
involve new and potentially complex work flows, are likely to be difficult for
many eligible professionals to understand and implement, or depend on
technologies that are not yet widely deployed or shown to be usable in busy
practices,” said Michael H. Zaroukian, MD, PhD, chair of the American College
of Physicians medical informatics committee.
The American Academy of
Family Physicians said the issues are serious enough that stage 3 should be
delayed until at least 2017. “Rather than prematurely impose stage 3
requirements, HHS should first focus on improving the ability for physicians to
achieve meaningful use stage 1 and 2 requirements,” wrote AAFP Board Chair Glen
Stream, MD.
No partial credit for some measures
Physicians already having trouble meeting core
and optional meaningful use measures in stage 1 will experience far greater
difficulties in the third phase of the program, the organized medicine groups
said. The committee’s proposal would nearly double the number of measures that
a practice must meet for every eligible patient encounter to avoid Medicare pay
penalties.
“Failing to meet just one measure by 1% would
make a physician ineligible for incentives and face the same financial
penalties during the penalty phase as those physicians who make no effort to
adopt EHRs,” the AMA stated in a Jan. 14 comment letter.
The AMA does not support the financial penalties,
which will lower Medicare pay by 1% in 2015 for physicians not using the
technology adequately by October 2014. However, the policy committee could
provide physicians with more options to prevent lower payments, the Association
stated.
For instance, similar regulations to the ones
adopted by the Centers for Medicare & Medicaid Services for electronic
prescribing and quality reporting programs would lower the number of physicians
penalized by the EHR initiative. Reporting e-prescribing activity during 10
eligible patient encounters over six months stops the pay cut in that program
even though it is not enough to secure a pay bonus. The AMA recommended that
physicians meet only 10 meaningful use measures to avoid that penalty, instead
of requiring them to meet all of the measures to be compliant.
Medical group administrators also believe that
the decision to set 2014 as the reporting year that determines the 2015
penalties should be revisited. Payment adjustments should be assigned the same
way bonuses are paid, wrote MGMA-ACMPE, the medical practice management
association, in a Jan. 14 letter.
“If penalties are to be assigned, we urge the
imposition of payment adjustments to start Jan. 1, 2016, for failing to meet
the 2015 meaningful use requirements,” the MGMA-ACMPE said. “We believe this is
the appropriate interpretation of the statute’s requirement that payment
adjustments begin in 2015.”
Dismissing EHR “science fiction”
Physicians and hospitals have been tasked with
purchasing EHRs and transitioning the health care system to paperless records.
However, there are gaps in the national health information technology network
that must be closed for doctors and facilities to meet the objectives, the
American College of Cardiology stated in its Jan. 14 comment letter.
“Without those pieces, much of what the [committee]
proposes seems more like science fiction than mere forward thinking,” the ACC
said. “Indeed, the proposals seem ambitious and imaginative, but almost
impossible to actually accomplish, especially without much in the way of
underlying data, interoperability and communication standards.”
The AMA recommended that the new standards for
stage 3 be optional and placed on a menu set, from which physicians can choose
measures to meet for meaningful use. For example, one such new measure would
require a physician to acknowledge receipt of external information when
receiving a patient referral at least 50% of the time. The physician then would
be required to return referral results electronically during at least 10% of
the encounters.
Measures requiring such communication could lead
to message fatigue and defeat the purpose of the meaningful use objective, the
ACC wrote. “While larger systems may not encounter difficulties with message
acknowledgements, small physician practices will be overwhelmed and could potentially
be distracted from providing the highest patient care.”
