The American Medical Association is asking the Centers for Medicare & Medicaid Services to revise the meaningful use program to better align with requirements of last year’s Medicare Access and CHIP Reauthorization Act (MACRA) and to allow for smoother transition to value-based payment models.
In a Dec. 15 letter to CMS, the AMA issued a list of recommendations for meaningful use Stage 3 that aim to address challenges with using electronic health records (EHRs) and to help move toward MACRA’s alternative payment models (APM) and Merit-Based Incentive Payment System (MIPS).
Dr. Steven J. Stack
“Doctors want to spend their time with patients, not measuring the number of clicks,” Dr. Steven J. Stack, AMA president, said in a statement. “We want a successful transition to digital health records, and we also want the new Medicare law to succeed. It will take thoughtful changes in the regulations to support physicians as they treat patients through new models of care.”
The AMA’s recommendations come in response to CMS’ final rule for meaningful use Stage 3, effective Dec. 15. The final rule simplified Stage 3 and gave doctors 1 more year – until Jan. 1, 2018 – to comply.
The AMA requested that CMS immediately adopt the association’s revisions for meaningful use Stage 3, including that the agency provide more flexibility and allow for multiple methods/paths to achieve desired end goals; remove threshold requirements for measures outside physicians’ control; and eliminate its pass-fail program design. Scrapping a pass-fail approach is the only way the ... program can align and operate within MIPS and APMs, Dr. James L. Madara, AMA executive vice president and CEO wrote in the letter.
Dr. James L. Madara
The AMA also criticized Stage 3 for taking a poor approach to interoperability. The current measures are too focused on the quantity of information moved and “not the relevance of exchanges or the underlying business case for transmitting data,” Dr. Madara wrote. The AMA wants the measures to be refocused to address specific instances of data exchange, such as closing the referral loop, team-based care, and notification of tests/admissions.
According to the AMA, CMS should:
• Re-orient measures away from process-based tasks to highlight goals that are useful to patients and physicians.
• Encourage new technology functions to be the focus of certification rather than placing requirements on physicians and patients that may not yet be feasible.
• Support the reuse of data to reduce the burden on documentation.
The AMA’s recommendations are in line with concerns by the American Academy of Family Physicians over Stage 3, according to Dr. Robert L. Wergin, AAFP board chair. In a Dec. 2 letter to CMS, the AAFP said the final rule fell short of expectations and, in fact, places further obstacles in the way of improved health, better health care, and lower cost.
Interoperability challenges remain a top concern with the program, Dr. Wergin said in an interview. He cited a 27% decrease in physician satisfaction with EHRs since the launch of the meaningful use program, according to a 2014 survey.
“The whole concept of electronic health records, as family physicians, we saw the potential to help us care for our patients and help us track their progress,” Dr. Wergin said. “I would call it a potential unrealized. It really hasn’t developed into what we thought it could do. There’s a lot of frustrations.”
The AAFP calls for CMS to hit the pause button on meaningful use until 2019 – long enough to allow:
• The health care industry time to focus on interoperability issues.
• Vendors, physicians, and other health care professionals time to focus on designing and implementing the functionality and work flows necessary to achieve value-based payment.
• Regulators time to modify meaningful use regulations and align them with pending MACRA rules.
Dr. Rocky D. Bilhartz
Similar concerns were expressed in a Nov. 20 letter from the GOP Doctors Caucus to Speaker of the House Paul Ryan (R-Wisc.). The 18-member caucus requested Speaker Ryan’s help in pressing for a delay of Stage 3 and a blanket hardship waiver exception for Stage 2. Implementation of more-stringent criteria is likely to create “a chilling effect on further EMR adoption as physicians conclude that the cost of implementation is simply not worth the bureaucratic hassle,” according to the letter. “Members of our caucus, as well as numerous congressional health care leaders, have engaged CMS on these issues to warn them of the potential negative consequences of placing these new requirements on providers in order to meet an arbitrary deadline. CMS has ignored Congress. Congressional action is the only solution left for preserving patient access, choice and quality.”