The increasingly unrealistic demands of meaningful use are leading to a groundswell of resistance. While 96,000 physicians have demonstrated meaningful use and earned EHR incentives, the majority did so while complaining about the negative impact that the Stage 1 “minimal” set of requirements had on their practice workflows. (See the results of a physician survey and read physicians’ comments in my last EMR Straight Talk post.) As Stage 2 approaches, those who have previewed the increasingly complex and demanding requirements are consumed by trepidation. Many are already considering abandoning meaningful use after they collect their $30,000 for Stage 1. Despite the fact that no one has yet had experience with the Stage 2 requirements, the Stage 3 proposal from the HIT Policy Committee is already out for public comment. Physicians and the professional organizations that represent them—already close to the breaking point—are crying “Uncle!”
The following is only a partial list of organizations that have commented: the American Medical Association, American Academy of Family Practice, College of Healthcare Information Management Executives, American College of Physicians, and the American Hospital Association. You can read their comments by googling the organization name and “Stage 3 comments” or “Letter to Mostashari.”
Although they phrase it in slightly different ways, all of these organizations are pleading with the powers that be to slow down what is perceived as a runaway train. Their comments center around several problems: lack of EHR usability, unrealistic and excessively complex requirements, the undue speed with which they are being imposed, and a lack of evidence of the program’s success. Physicians see the program as a massive data collection and reporting project with no proven quality improvement outcomes attached to it. Unless the government pays heed to the concerns and recommendations being voiced, the EHR incentive program is doomed to failure. Physicians will simply toss in the towel.
The following is a description of the most common sentiments expressed in the letters and formal comments:
- Stage 3 should not even be considered until the experience of Stages 1 and 2 can be evaluated to see what was actually accomplished and what the cost is to physicians. Many are calling for an independent assessment of the program. It is not sufficient to merely gloat about how successful the successful meaningful users were—an analysis must be conducted to investigate why other physicians were either not successful or chose not to even attempt to achieve meaningful use.
- In addition, Stage 3 should not occur until at least 3 years after Stage 2, giving physicians and vendors sufficient time to move forward.
- EHR usability is identified as a major issue in every set of comments. EHR de-installs are increasing in number as physicians abandon legacy systems. The impact of a lack of usability is compounded when physicians attempt to use an already challenging system to meet an overwhelmingly challenging set of requirements. When workflow is negatively affected, the costs to physicians can quickly exceed the benefits.
- The AMA suggests that the government conduct user-satisfaction surveys—by practice type, size, and specialty—and incorporate the results into the certification requirements going forward.
- Meaningful use remains a primary-care program that, despite the addition of a few specialist-focused measures, does not adequately recognize specialists’ unique workflows. They resent being asked to report on measures that have minimal, if any, value to their practices.
- As the requirements become increasingly complex, it may be time to modify the “all or nothing” approach, and reward physicians for reasonable levels of success. Penalties should be eliminated, or at a minimum, significantly delayed.
Don’t sit back and wait for the Stage 3 rules to be finalized. Express your opinions either by writing to your professional organization or directly to Dr. Farzad Mostashari. It is critical to keep up the pressure on the decision makers.