The American Medical Association has asked the CMS and the Office of the National Coordinator for Health Information Technology at HHS to hire an outside evaluator to take a look at the federally funded electronic health-record incentive payment program.
Meanwhile, the AMA has called on the feds to stop raising the bar on payment qualification criteria until any issues raised in the evaluation are identified and publicly aired.
The request came in a 20-page letter
from AMA Executive Vice President and CEO Dr. James Madara to ONC chief Dr. Farzad Mostashari in public comments about the recommendations for Stage 3 meaningful-use requirements submitted to ONC in November by the federally chartered Health IT Policy Committee.
The Health IT Policy Committee advises the national coordinator on policy matters, including the meaningful-use criteria that hospitals, physicians and other “eligible professionals” must meet to qualify for incentive payments under the act.
“We realize and appreciate the amount of time that the members of the Health IT Policy Committee and work groups have spent to thoughtfully consider, develop and recommend measures for stages 2 and 3,” Madara wrote. “Nonetheless, we believe that it is a serious mistake to keep adding stages and requirements to the meaningful-use program without evaluating Stage 1 of the program.”
“An external, independent evaluation of Stage 1 of the program prior to the development of Stage 3 requirements will help to identify: measures that make sense and can be reasonably achieved; functionalities that vendors can build into EHRs and the time frame required to build, test and fully implement these functionalities; and meaningful-use requirements that are reasonable for CMS and ONC to propose and pursue,” he said.
HHS should use its “regulatory authority” to “hold off developing Stage 3” of the program until an evaluation of Stage 1 can be completed “and the results and recommendation for resolving issues that are identified are shared with the public for their feedback.”
Subsequent stages also should be evaluated “prior to finalizing the requirements for the next stage,” Madara said. “It makes no sense to add stages and requirements to a program when even savvy EHR users and specialists are having difficulty meeting Stage 1 measures.”
The AMA also called for more attention to be paid to EHR usability when systems are tested and certified for use under the incentive payment program. It also called for modification of the 100% pass/fail requirements for meaningful-use criteria and more work on improvements in health IT infrastructure to better able physicians to share patient data, “which is essential for improving the value and efficiency of our healthcare delivery system.”