Leading Organizations Comment On Stage 3 Meaningful Use

Stage 3 Meaningful Use CommentsComments On Stage 3 Meaningful Use

Yesterday the American Medical Association (AMA), the College of Healthcare Information Management Executives (CHIME), the American Hospital Association (AHA) and the Healthcare Information and Management Systems Society (HIMSS) all sent letters to ONC’s Farzad Mostashari giving detailed comments in response tothe Health IT Policy Committee (HITPC) request for comments on Stage 3 Meaningful Use requirements published in the Federal Register on November 26, 2012. The deadline for submitting comments was last night, 11:59 p.m.

You can read each organizations letter below:

In  the AMA’s 20-page letter, the organization lists five primary concerns from feedback received from physicians:

  1. 100 percent pass rate is not the right approach “Failing to meet just one measure by one percent would make a physician ineligible for incentives and subject to financial penalties.”
  2. One size does not fit all “Every physician regardless of their specialty must meet the core measures with few exceptions.”
  3. Evaluation process is lacking AMA is recommending an external, independent evaluation is necessary of the program.
  4. Usability of certified EHRs AMA wants more attention paid to physician usability concerns during certification process.
  5. Health IT infrastructure barriers AMA recommends that improving Health IT infrastructure for secure exchange of patient data should take precedence over development of Stage 3 meaningful use and any future stages.

The AMA responses also details the organizations recommendations for “improving the Meaningful Use Program.” These recommendations begin on page 10 of the AMA letter.

CHIME gives comment responses to each HITPC Stage 3 meaningful use recommendation following the organization’s letter. Their letter concludes with a statement of the organization’s concern over audits of EHR incentive payments:

Lastly, CHIME is concerned that asymmetric auditing efforts that exceed certification requirements could risk hospital and EP loss of EHR incentive payments. In our view, audits should be primarily focused on uncovering fraudulent activities, not honest mistakes in documentation, especially at this early juncture in EHR meaningful use and when documentation requirements are being specified or made clear only after the fact. Instead, the Department needs to be collaborating with the hospitals and health professionals who are making good-faith efforts to adopt and meaningfully use certified EHR technology, and this collaboration should extend to the identification of “common sense” ways for documenting that meaningful use requirements have been met.

In the letter from HIMSS the organizations addresses Stage 3 meaningful use timing issues.

We encourage the government to ensure that eligibility requirements for meaningful use are clear and realistic. As the government develops its Stage 3 NPRM, we request that the Final Rule be published at least 18 months before the beginning of the required implementation period. This will allow adequate time for developers to make the needed technology changes, for the industry to develop its response, for certification, to occur, and for providers to plan and implement required software and process changes.