Physicians said enough is enough and submitted their own revisions to Stage 3 of the electronic health record (EHR) meaningful use program in a letter Tuesday, which would address real-world needs of physicians and patients. The letter outlines several detailed ways the program needs to change in light of the program’s impact on the design of EHRs, the movement toward new payment and delivery models, and the quality of patient care.
Earlier this year, Stage 3 of the meaningful use program was finalized against the recommendations of the physician community. In response, the AMA submitted a comment letter (log in) Tuesday to the Centers for Medicare & Medicaid Services (CMS), outlining a framework for a more practical meaningful use program.
The comment letter seeks to alleviate meaningful use burdens and revise the program to improve flexibility, expand patient engagement, and clear the way for increased health IT interoperability and innovation.
The recommended changes would improve the program for both physicians and patients. They include:
- Provide flexibility and eliminate the program’s pass-fail design
- Expand measures to promote patient engagement and interoperability
- Remove requirements that are beyond physicians’ control
- Reorient measures away from process-based tasks to highlight goals that are useful to patients and physicians
- Focus certification on new technology functions rather than placing requirements on physicians that may not be feasible yet
- Support the reuse of data to reduce the physicians’ documentation burden
The letter points out that new payment systems, such as the Merit-Based Incentive Payment System (MIPS) and alternative payment models (APM) established in the Medicare Access and CHIP Reauthorization Act (MACRA), will not work under the current pass-fail design, in which physicians are penalized for failure to meet just one of many requirements and are held accountable for measures not in their control. Increasing flexibility should ensure more successful participation and ease the implementation of new payment models in the future, the letter states.
It’s no surprise that patient engagement is a major focus of the recommended revisions as well. The outline calls for broadening patient engagement measures to include the “numerous innovative ways that patients and physicians can communicate and connect with one another.”
“Instead of having multiple measures that overlap,” the letter states, “we urge CMS to adopt a single expanded measure that would include activities beyond viewing, downloading and transmitting data.”
A revision of Stage 3 could include measures focused on reviewing clinical notes; accessing information about labs, tests and prescriptions; viewing cost information; and scheduling appointments and paying for services electronically. The measure should not dictate which type of technology must be used, the letter urges. “We believe such criteria stifle new approaches and will become quickly outdated.”
The recommended revisions focus on what EHR technology should accomplish, rather than on data entry requirements.
The requirements for computerized provider order entry and clinical decision support, which currently are focused on counting data entry, can add ongoing challenges to practice work flow. Although CMS tried to mitigate some of these problems in Stage 3 requirements, the measures still need greater flexibility to remove these work flow challenges and ensure relevance to all physicians.
The AMA proposed the following revised measure:
- Physician-designated staff should be allowed to electronically enter medication, lab and radiology orders. These orders should be processed electronically without intervention.
- Physicians should have a choice in selecting at least one clinical decision support tool and the information that is taken into account. Clinical decision support should not only be tied to quality measures and should not be required for the entire EHR reporting period.
“Changing the focus away from data entry and toward actual processing of the order will help ameliorate [some] concerns and improve productivity,” the letter states. However, this will require advancements in interoperability. As a solution, the letter urges the Office of the National Coordinator for Health IT (ONC) to establish a more focused approach for testing the interoperability of health IT at the point of development to promote better user-centered design.
Also flagged for revision are the qualified clinical data registry measures. The framework recommends that physicians, particularly specialists, who participate in a qualified clinical data registry should be deemed as successfully meeting the meaningful use quality requirements.
Additionally, because CMS has not updated the electronic clinical quality measures list in years and does not plan to do so again until 2017, the AMA recommends scaling down the number of quality measures required to report until there are enough electronic clinical quality measures that work for all physician specialties.