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AMA, Medical Societies Urge Stage 3 Meaningful Use Delay

By Kyle Murphy, PhD

UPDATE: CMS issued the final rule for meaningful use modifications on October 6.

The American Medical Association (AMA) and 41 other medical societies have called on the Department of Health & Human Services (HHS) and Office of Management and Budget (OMB) to delay finalizing Stage 3 Meaningful Use but move forward with publishing modifications to meaningful use requirements for reporting years 2015, 2016, and 2017.

In two identical letters to HHS and OMB, the 42 organizations have expressed their concern about the "current direction" of the EHR Incentive Programs, including its impact on the implementation of value-based care models and programs such as the Merit-Based Payment System (MIPS) and Alternative Payment Models (APMs).

"There are so many questions surrounding creation of MIPS and APMs that it is premature to proceed with MU Stage 3, especially since EHRs and MU will serve as a foundation for the success of these programs," they write to HHS Secretary Sylvia Burwell and OMB Director Shaun Donovan.

A main contention of the group is the potential for current EHR certification criteria to limit the long-term benefits of certified EHR technology for other uses beyond the EHR Incentive Programs:

If the administration finalizes the proposed MU Stage 3 regulation now, vendors will create software that will lock-in problematic technology, which physicians and patients will be living with for years to come. The proposed MU Stage 3 regulation exacerbates problematic policies of MU Stage 2 by continuing to “count” physicians’ compliance with one-size-fits-all objectives rather than focusing on the clinical activities that should support differences in medical practices and patient care. We believe Stage 3 takes a drastic step backwards from the proposed improvements of the Modifications Rule.

The group also contends that the timing of the final rules development is problematic.

"Moreover, the proposed MU Stage 3 regulation was developed prior to and without consideration of the changes enacted by the Medicare Access and Chip Reauthorization Act (MACRA)," the letters state. "Yet, the MU program will play a vital role in both the new MIPS payment system and the development of APMs."

This is the motivation behind one of the three recommendations advocated by the AMA and 41 medical societies.  "The administration should therefore pause MU Stage 3 and reevaluate the program in light of these pivotal changes to Medicare," they urge.

The group's second recommendation stems from the belief that delaying Stage 3 Meaningful Use will neither stop nor delay EHR adoption but instead "help move the program forward and drive innovation and adoption" — finalizing meaningful use modifications.

"To continue to advance EHRs, we urge the administration to proceed with finalizing the Modifications Rule as well as with integral pieces of the proposed 2015 Edition Certification Rule as soon as possible," the collection recommends with the belief that delays jeopardize the more immediate impact EHR technology on healthcare delivery.

Given the lateness of finalizing these changes to meaningful use requirements, the 42 organizations are asking HHS to "establish an additional hardship exemption category for physicians who could not anticipate new program mandates so late into the year."

Although not a recommendation, the group makes clear its disapproval of HHS's approach to advancing interoperability:

There seems to be a view among some policymakers that by requiring more certified EHRs to populate the landscape the systems will achieve interoperability. The physician community strongly disagrees, and we are concerned that spreading poor performing systems may exacerbate the problem. Instead, we believe key interoperability challenges need to be addressed first so that the systems entities adopt will be capable of facilitating the seamless exchange of data. We believe that pausing Stage 3 at this time will provide the opportunity to evaluate the environment as we work with the administration to implement the needed changes found in the Modifications Rule.

OMB received the Stage 3 Meaningful Use and meaningful use modifications final rule on September 3, which is still pending review.




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