AMA Releases Meaningful Use Stage 3 Blueprint

Ken Terry

October 17, 2014

Ahead of the release of the proposed rule for stage 3 meaningful use of electronic health records (EHRs), the American Medical Association (AMA) has released a blueprint for the future of the EHR incentive program that includes both recommendations for stage 3 and a call for fundamental changes in stages 1 and 2 of meaningful use.

The blueprint was laid out in an October 14 letter to Marilyn Tavenner, administrator of the Centers for Medicare & Medicaid Services (CMS), and Karen DeSalvo, National Coordinator for Health Information Technology.

In all three meaningful use stages, the AMA wants CMS to replace its all-or-nothing approach to meeting the program criteria with one in which physicians would have to meet 75% of the criteria to obtain incentive payments and 50% of the requirements to avoid penalties for not showing meaningful use.

The association also wants CMS to make optional the "view-download-transmit," transitions of care, and secure messaging criteria in stage 2. The requirements that physicians ensure that 5% of their patients view, download, or transmit their health information electronically and message their physicians online have been controversial because patients' actions are outside their doctors' control.

Similarly, the requirement that physicians provide care summaries online in 10% of transitions of care (and at least once with a disparate EHR) requires a level of interoperability that does not yet exist in most places, the AMA letter notes.

Furthermore, the AMA calls for improved alignment of quality reporting between the meaningful use program and the Physicians Quality Reporting System; better methods for practices to report quality data electronically to CMS; elimination of quality measures that don't follow the latest evidence; testing of quality measures in the field; and more public input into new quality measures.

The AMA also wants CMS to expand its hardship exceptions in all meaningful use stages. In addition, it requests the Office of the National Coordinator for Health IT (ONC) to revamp the EHR certification program to focus exclusively on interoperability, quality measure reporting, and privacy/security.

In stage 3, the AMA recommends that CMS and ONC eliminate the difference between core and menu metrics. The AMA would also remove percentage thresholds for meaningful use measures because they increase administrative burdens and distort clinical workflows, the group says. Instead, the AMA would expand the number of measures physicians could select from to help specialists participate in meaningful use, but physicians would only have to meet a total of 10 objectives.

Arguing that current ONC policies have impeded rather than enhanced interoperability among disparate EHRs, the AMA is asking for thorough, real-world testing of interoperability standards before they're implemented. The trade group notes that the current ONC-approved standard for care summaries, the C-CDA, was never properly vetted. A recent study showed that "EHR-generated C-CDAs scored on average only 63 percent in accuracy," the letter says.

ONC should also demand greater usability from EHR vendors, the AMA maintains. Noting that current EHRs do not support bidirectional information transfer or measurement, the letter states, "We recommend that requirements be included in [meaningful use] stage 3 that support the referral process within a system and to external specialists through the EHR."

Overall, the AMA adds, "Stage 3 should recognize the need to focus less on data collection and more on methods and technologies that facilitate the coordination of care and new data models."

AMA has offered some of these ideas before — notably, its objection to the all-or-nothing approach — and it has vigorously lambasted some meaningful use requirements before. But this blueprint represents the most detailed and sophisticated critique of the EHR incentive program it has provided so far.

Not surprisingly, the AMA blueprint was delivered only a few months after Robert Wah, MD, was named president of the organization. Dr Wah is a nationally recognized health IT expert who still works for CSC, an international consulting firm.

Commenting on the blueprint in a news release, Dr Wah said, "While more than 78 percent of physicians are using an EHR, thousands have not participated in the Meaningful Use program or attested to Stage 2, in large part because of the program's all-or-nothing approach.

"Physicians should not be required to meet measures that are not improving patient care or use systems that are decreasing practice efficiencies," Dr Wah said. "Levying penalties unnecessarily will hinder physicians' ability to purchase and use new technologies and will hurt their ability to participate in innovative payment and delivery models that could improve the quality of care."


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