The AAFP recently called on the Office of the National Coordinator for Health Information Technology (ONC) to delay implementation of meaningful use (MU) stage three requirements until at least 2017 and to delay or eliminate all penalty provisions.
In a frank comment letter(11 page PDF) dated Jan. 10 and addressed to ONC National Coordinator Farzad Mostashari, M.D., AAFP Board Chair Glen Stream, M.D., M.B.I., of Spokane, Wash., confirmed that the AAFP is a long-standing proponent of the use of electronic health records (EHRs) to drive improvements in quality, safety and efficiency in health care delivery.
However, Stream pointed out that HHS delayed implementation of MU stage two regulations until 2014, and he suggested that a corresponding delay in MU stage three rules should follow.
"We remain concerned that HHS is attempting to raise the bar for what constitutes meaningful use before the majority of physicians and hospitals are able to achieve the meaningful use stage one or two objectives," said Stream.
- In a recent comment letter, the AAFP asked the Office of the National Coordinator for Health Information Technology (ONC) to delay implementation of electronic health record meaningful use (MU) stage three requirements until at least 2017.
- The AAFP called on the ONC to delay or eliminate all MU stage three penalty provisions.
- The AAFP does not support any future stages of meaningful use beyond MU stage three rules, said the letter.
He urged HHS to "focus on the hard problems that require coordination" rather than wasting resources on criteria such as computerized provider order entry systems, demographics, lab results, and counting and verifying electronic prescriptions.
He called on the ONC to promote simplicity rather than complexity. "The health information technology industry has a proven propensity to overdesign and underdeliver," said Stream. "The AAFP believes that for physicians to optimize value for their patients, vendors must first optimize value for their users."
Stream stressed that physicians should be encouraged to use high-functioning EHR systems at full capacity; doing so would mean that MU stage three measures would not require tedious manual record keeping.
"If something is worth doing, then it is worth doing most of the time," said Stream. "If HHS is to require family physicians to invest in and implement a significant process change, it should be relevant for the majority of times they perform a clinical task."
With that in mind, the AAFP suggested that any measure that could not be implemented with -- and kept at -- a performance threshold of 50 percent should not be considered mature enough for the meaningful use program.
"We recommend implementing measures that have broad, clinically proven impact, leaving experimentation to other programs," said Stream.
The AAFP also chided HHS for its use of highly prescribed requirements and broadly applied penalties and said that using such requirements and penalties would not "foster sustainable growth of quality improvement practices by clinicians."
Rather, said Stream, "We recommend development of a foundational clinical guideline, clinical quality improvement, clinical decision support framework and its implementation through value-based incentives, not meaningful use."
In addition, the AAFP commented on a number of specific objectives in the regulation, including those related to
- demographic elements,
- clinical decision support,
- advance directives,
- lab interface with eligible professionals,
- patient follow-up and prevention reminders,
- electronic note documentation,
- episodes of care and care plans,
- communication barriers, and
- secure messaging by patients.
Stream said the AAFP does not support future stages of meaningful use. "After stage three, sustainable payment models should be used by HHS to drive care delivery reform, not prolongation of the artificial models of meaningful use."
He called on HHS to "re-evaluate the perceived need to create and enforce a complex set of rules to manage behavior."
"The vast majority of EHR users will do the right thing when it is the easy thing," said Stream. "Though the financial incentives are now available, clinicians are acutely aware that with each stage of meaningful use, safety, quality and efficiency do not appear to be any closer, and for many practices, the true cost of EHR technology is far greater than the incentives available."
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