The American Medical Association (AMA) and 98 state and specialty medical societies today submitted formal comments on the proposed rule outlining the measures that physicians have to meet to qualify for financial incentives in Stage 2 of the Medicare/Medicaid meaningful use electronic health record (EHR) program.
“The AMA is supportive of widespread adoption and meaningful use of EHRs by physicians, but the cumbersome proposed criteria will make successful physician participation extremely difficult," says AMA board chair-elect Dr. Steven J. Stack. “Due to physicians’ limited ability to exchange data with other healthcare partners, many of the proposed Stage 2 measures will require extensive manual data entry, which is not an efficient way of practicing medicine or improving quality care outcomes for patients."
To make the Stage 2 program more reasonable and achievable, the comment letter makes the following principal recommendations:
• Evaluate Stage 1 to inform the final Stage 2 requirements
• Create more flexibility in meeting measures including exclusion and relevancy factors
• Delete the high thresholds for new measures and for measures that cannot be met due to the lack of available, affordable, well-tested tools or exchange capabilities
• Incorporate more focus on measures within a physician’s control
• Include any proposed new measures for Stage 2 in the menu set of options
• Allow a significant good faith effort to meet measures in Stage 2 to count for incentives and for avoiding penalties
• Eliminate back-dating the meaningful use penalty program and establish a number of exemption categories for hardship cases
• Synchronize and improve the overlapping health IT and quality program requirements
• Establish an appeals process under both the meaningful use and e-prescribing programs
• Reduce the burden and add flexibility in regard to clinical quality measure (CQM) reporting and requiring testing of electronic specifications prior to use of a CQM.
“Overall, the proposed Stage 2 requirements need to provide more flexibility to foster widespread EHR adoption," Stack asserts. “Physicians are at varying stages of implementing health IT into their practices and should get credit for making a good faith effort to meet the meaningful use requirements."