Med Societies Urge Restraint, Changes for “Meaningful Use”
A letter of comments sent by 96 specialty and state medical societies urges the Centers for Medicare & Medicaid Services (CMS) to reconsider some aspects, saying the Stage 1 electronic health record (EHR) incentive program is too aggressive.
The letter is one of the comments requested by CMS for the proposed “meaningful use” criteria meant to define standards for implementation of EHR systems in physician practices and facilities. Providers and facilities treating Medicare and Medicaid patients stand to receive up to $44,000 by the 2014 deadline, according to the American Recovery and Reinvestment Act of 2009 (ARRA), or stimulus package, which became law in February 2009.
The societies said in their letter that, “Successful integration of EHRs and health IT into patient care takes time and depends on whether or not the methodology employed to achieve integration enhances performance and accurately reflects and supports the work of patient care.”
The 37-page letter calls for the following to ensure successful integration of EHRs:
- Reasonable timelines and criteria for Stage 1
- Small physician practice representation on the Health IT Policy Committee
- Feedback loop on performance, alerting physicians early on if the information requested is not received properly
- Staged approach to achieving meaningful use
- Reconsideration of numerators and denominators that are expected to require significant manual tracking by physicians
- Evaluation of Stage 1 before requiring compliance with Stage 2
- Develop a multi-pronged communication process to educate providers about incentive programs and meaningful use
- Clarify and simplify participation requirements for providers and their attestation for meaningful use
- Encourage CMS to take into account practice size, specialties, and locations in enforcing the initial EHR reporting period
- Reconsider the definition for a hospital-based eligible provider to allow physicians who may be hospital based but also have their own practice to be eligible to receive incentive payments for their practices
- Develop a simple, web-based tool allowing providers to determine their eligibility before starting Stage 1
- Establish an appeals process so physicians can dispute determination regarding their eligibility
- Permit physicians to revise their status, changing their eligibility, in mid-year so they can take part in the incentive program
The group also asks CMS to reconsider measures regarding computerized physician order entry (CPOE), which allows the physician to enter medical orders such as medications, lab services, consultations, imaging studies, and others. The group maintains some measurements, such as those regarding medical orders and prescriptions, conflict. The group expressed worry that gathering all the information from both paper and electronic systems to achieve the 80 percent requirement for CPOE compliance was too consuming. They also expressed concern about how the presence of the screen would interrupt the patient-physician interaction in the exam room. As a result, the group asks that Stage 1 of meaningful use require one test of CPOE rather than 80 percent of patient visits.
Concerns about a 75 percent threshold for prescriptions, an active medication list, and a lack of standards for electronic prescriptions also alarmed the group. Questions about measures reporting and development, where elements of the evaluation and management (E/M) visit are recorded, standardized reminders, quality metrics, and several other topics also are raised in the letter.