While providers are still struggling with the details of meaningful use Stage 1—and as of yet, no one has actually demonstrated meaningful use of their EHR—plans for defining Stage 2 requirements are moving ahead at full speed. A preliminary set of recommendations was released by the Meaningful Use Workgroup of the HIT Policy Committee in January, along with a Request for Comment by February 25. And comment they did!
Major organizations representing the various stakeholders submitted lengthy letters detailing their recommendations. While the specific concerns they express differ slightly, a clear consensus is emerging:
- Rushing providers to do too much too quickly in the next stage will be counterproductive to the end goal of successful and widespread EHR adoption, as well as have a negative effect on patient care.
- The proposed timelines are too aggressive in several areas.
- Expectations should not exceed the existence of a sufficient information-exchange infrastructure, e.g., syndromic surveillance is identified as unrealistic.
- Stage 2 requirements should be based on an objective evaluation of the experience in Stage 1 and the value of individual measures.
The last point above reveals a sense of frustration over the fact that the existing timetables create pressures that do not allow for this approach. Without taking into consideration the successes, failures, and physician participation rate in Stage 1—including, I would add, the rate of participation by specialists—Stage 2 could lay the groundwork for failure.
The AMA’s letter on behalf of 39 medical societies reiterates those societies’ initial concern about the excessive burden being placed on physicians. The letter argues for increasing flexibility, expanding the ability to opt out of measures that are not relevant to a physician’s routine practice, retaining a menu set rather than making all measures core and therefore required, and limiting physicians’ responsibility to what is within their control and not subject to compliance by other parties (e.g., patients’ use of portals for access to health information).
MGMA identified many of the same concerns, adding a request for harmonization of government programs to eliminate duplication of effort. (See discussion of this topic in my last EMR Straight Talk post.) Premier, Inc., a provider alliance, urged that new no clinical quality measures should be added until Stage 1 performance can be evaluated.
From the IT industry, AHIMA (an organization of healthcare IT professionals) cautioned about the impact of the overwhelming number of complex initiatives that practices will have to incorporate at the same time—ICD-10, Healthcare Reform, and meaningful use. EHRA, the EHR vendor trade organization, not surprisingly expressed its concern about the time needed to develop the software updates that will be required, particularly in light of the impending regulations identified by AHIMA. It therefore recommended that Stage 2 be limited to increased thresholds for Stage 1 measures with no addition of new measures. EHRA specifically identified clinical decision support as an area in which the government’s expectations go well beyond the scope of an EHR. As an overarching recommendation, EHRA urged a delay in the start of Stage 2 and the extension of certification to three years instead of two.
A somewhat different perspective comes from consumer organizations. The Consumer Partnership for eHealth and the Campaign for Better Care, on behalf of a number of other groups such as AARP and several unions, argue for a significant raising of the bar and accelerating of the program. For example, they ask that all menu measures become core measures, patient and family engagement via use of portals be emphasized, and clinical decision support rules be defined and adherence required. Deborah C. Peel, MD, Founder and Chair of Patient Privacy Rights, submitted a letter expressing her disappointment that “the current MU Stage 2 criteria and schedule for MU Stage 3 criteria completely ignore/omit privacy rights and protections in existing privacy law . . .“ It is not surprising that these groups would take a more aggressive stance and have higher expectations—these are the people who are paying for this program.
How will all of the above positions be reconciled? Based on the experience of Stage 1, in which the HIT Policy Committee and CMS revised the initial requirements to make meaningful use more achievable, I believe that they will do the same for Stage 2 and create a set of rules that are beneficial to the overall healthcare system and patients, while not overly burdening physicians.