In a recent letter to HHS Secretary Alex Azar, the EHR Association (EHRA) commended the majority of recommendations proposed in the federal agency’s draft strategy designed to reduce clinician burnout related to EHR use.
“As HHS takes important steps toward reducing clinician burden, it is important to recognize that a key contributor to the frustration of providers with EHR documentation requirements has been compliance with outdated guidelines which are geared to billing and policy requirements rather than patient care,” maintained the association.
“The current proposed Strategy and CMS's Patients Over Paperwork initiatives are welcome steps toward more focused documentation requirements,” added authors of the report.
While EHRA supports efforts to reduce regulatory burden by modifying billing requirements, EHRA stressed that any changes should be gradual and introduced at a measured pace.
“Most EHR clinical documentation capabilities for visit services are embedded in documentation elements and visit acuity scoring algorithms of E/M services,” stated EHRA.
“As with all changes that are introduced to health information and technology, especially those that impact clinical workflows, clinicians and clinical support staff need time to learn about the changes and adapt to using new, less prescriptive approaches,” continued the association.
Additionally, EHRA suggested HHS provide details of any planned changes to billing requirements well in advance of any reporting requirement deadlines to give clinicians enough time to prepare for the changes.
The association also stated its support for recommendations in the report promoting collaboration between HHS and clinical stakeholders in the adoption of best practices related to documentation requirements.
However, the association disagreed with certain proposals in the draft related to health IT usability and user experience.
Specifically, EHRA stated a suggestion from HHS to better align EHR design with real-world clinical workflows is in conflict with a recommendation to to standardize clinical content in health IT.
“Real-world clinical workflow varies across settings of care and clinical providers, and may not be a measurable recommendation,” wrote EHRA. “In the same way that driving a car differs in the user experience from driving a motorcycle, EHR systems may have different user experiences designed to be as optimal as possible for the users, clinical workflows, and settings for which it was designed.”
“This tradeoff between consistency and fit is one that we as developers are well-positioned to understand because of our intense investment in user research and understanding of the context of use,” added EHRA.
Instead, EHRA offered a white paper titled “EHR Design Patterns for Patient Safety” as reference material for potential ways to reduce clinician burden and addressing alert fatigue while also allowing for variation in EHR design and use.
“We appreciate HHS’ focus on clinician burden reduction,” concluded the association. “Thank you for this opportunity to provide our input. We welcome additional opportunities to share our expertise as this initiative moves forward.”
Pew Charitable Trusts also submitted a comment letter in response to the HHS draft strategy to reduce clinician burden related to EHR use.
The organization recommended ONC improve EHR usability and promote application programming interface (API) use to curb regulatory burden on clinicians.
To boost EHR usability and reduce the likelihood of patient harm, Pew recommended ONC ensure some criteria criteria part of the EHR Reporting Program focus on safety.
Pew also suggested ONC take steps to ensure APIs used to extract data from patient health records can effectively enhance health data exchange, reduce clinician burden, and improve the quality of patient care.