The American Medical Association asks for a lot of Meaningful Use Stage 2 changes.
As is customary, when HHS put out its proposed rule for EHR Meaningful Use Stage 2, it invited comments. AMA posted theirs this week in a letter that runs to 37 pages and is co-signed by 100 affiliated associations, including state medical associations and professional practice groups. (AMA sent a shorter letter on this subject in March.)
While AMA says they "share the Administration’s goal of wide-spread EHR adoption," they worry the present approach will "actually discourage physician participation in the meaningful use EHR program rather than encourage it."
Their recommendations are quite sweeping and include:
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Survey both adopters of and abstainers from EHR;
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Evaluate "value, risks... evidence of efficacy, administrative burden," etc., before adding or transitioning core measures;
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Add exclusion categories, and allow EPs to "opt-out" of measures irrelevant to their practices;
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"Measures based on patient’s use of technology" be eliminated;
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"Good faith effort to meet measures in Stage 2 should count";
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End back-dated penalties;
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Establish an appeals process.
AMA also has detailed recommendations on Clinical Quality Measures, including that EPs be exempt from CQM requirements "until measures have been tested and vendors have shown they have met the certification requirements for the specific EHR Technology being utilized by an EP."
The docs also don't like that CMS lifted thresholds for Meaningful Use 2 by as much as 40%, and want such raises restricted to 10%, and that only after thorough review. And they feel that forcing doctors to apply MU measures to all their patients when CMS will only reimburse them for Medicare patients is unfair and "not supported in statute."
Most measures get an AMA alternate suggestion. For example:
EP Menu Measure 1: More than 40 percent of all scans and tests whose result is one or more images ordered by the EP during the EHR reporting period are accessible through Certified EHR Technology.
Recommendation for Menu Measure 1: We support this measure in the Stage 2 menu set but recommend that the threshold be decreased to 20 percent and that the numerator and denominator be further clarified.
Each of these suggestions comes with a lengthy, detailed explanation.
To some extent, AMA is helpfully pointing out inconsistencies -- such as provisions that seem to steer doctors into HIPAA violations -- that make the EHR program unattractive (and surveys show it remains unattractive to many doctors). But the letter is also a negotiating position. Its key themes are these: They want more flexibility for doctors to choose their own way of meeting the spirit of meaningful use, and they want CMS' MU measures vetted by the profession and justified by CMS.
AMA is asking for way more than it expects to get, but it will have to get something.