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'Meaningful Use' Rule Needs Significant Modifications, Says AAFP
Some Elements Would Impede Goals of Health IT Legislation
By News Staff
In a Feb. 26 letter (7-page PDF; About PDFs) to CMS Acting Administrator Charlene Frizzera, AAFP Board Chair Ted Epperly, M.D., of Boise, Idaho, began by lauding CMS and the Office of the National Coordinator for Health Information Technology for the amount of energy expended to craft the regulations and the "potential health IT progress made possible with these regulations."
However, Epperly continued, "We believe that certain aspects in the details of these regulations are unworkable, excessive, or redundant and will actually impede the very goals of the legislation."
Improving Meaningful Use Regulations
- offering partial incentives for physicians using less than 100 percent of required criteria,
- creating parity between first-year requirements for the Medicare and Medicaid programs,
- changing calculations of meaningful use measures from recording of percentages to absolute counts or allowing for shorter 30-day reporting periods, and
- ensuring incentives for team-based care.
Regarding the AAFP's call for partial incentives, Epperly said he was "greatly concerned about the capacity for many eligible providers, especially those in small and medium practices, to achieve all of the required criteria by 2011 and 2012." He added that CMS could miss a huge opportunity with its "all-or-nothing" approach. Epperly said the AAFP did not want to discourage practices that couldn't achieve 100 percent of the requirements "from using, improving or implementing EHRs because they will receive no incentive for anything less."
The Academy had no issues with CMS' meaningful use goals but expressed concern about the proposed administrative burdens that would be placed on physicians to report the measures. "We strongly believe that efforts and resources in the practice need to be focused on the transformation of the practice and achieving high-quality care -- not on tracking denominators for process measures," said Epperly.
In terms of team-based care, Epperly asked for revised wording that wouldn't require a physician to actually perform a task, but rather would make the physician responsible for ensuring completion of the work. This change "is critical to patient-centered care via a team-based approach to care," he said.
Comments on Specific Meaningful Use Goals
For example, the proposed rule has an objective on computerized provider order entry, or CPOE, that would require computerized entry for at least 80 percent of orders.
"We believe that the administrative burden to report on the CPOE measure is excessive to the point of being unachievable for most eligible providers," said Epperly. He noted that most physicians would have to perform double-data entry because many labs, hospitals and diagnostic imaging centers do not accept standard electronic orders.
"Based on the current state of adoption of CPOE in the ambulatory environment …we recommend that the CPOE measure be removed until electronic orders are routinely transmittable," he said.
The AAFP also took issue with a measure requiring that at least 75 percent of prescriptions be transmitted electronically. Epperly pointed out that many physicians with e-prescribing capabilities don't use the technology because of pharmacy or patient resistance. In fact, only about 16 percent of prescriptions are sent electronically; therefore, the 75 percent threshold is likely unachievable by the majority of physicians "because of conditions not under their control," said Epperly.
The Academy recommended that the e-prescribing measure be reported with an absolute count of e-prescribed medications rather than a percentage of total prescriptions.
Epperly also suggested changes in other measures, including
- recording patient demographics and vital signs,
- incorporating clinical lab test results,
- generating patient lists by specific conditions,
- implementing five clinical decision support rules,
- providing patients with electronic copies of their health information, and
- giving patients electronic access to their health information within 96 hours after a patient visit.
"We believe there is a real risk for entities to gouge eligible providers to 'assist' them with such testing," he added.
Epperly asked CMS to significantly modify the proposed rule to ensure participation by a majority of physicians. Doing so would move America more quickly toward a patient-centered, coordinated and high-quality health care system, he said.
Federal Government Issues New Health IT Regulations
CMS Proposes Definition of EHR 'Meaningful Use'
Health Care Stakeholders Struggle to Define 'Meaningful Use'
Federal Government's Incentive Payments to Docs Hinge Wording
Health IT, Primary Care Come Out Ahead in Massive Stimulus Bill
Approved Legislation Addresses Key AAFP Issues
Markle Foundation Consensus Statement: "Achieving the Health IT Objectives of the American Recovery and Reinvestment Act -- A Framework for 'Meaningful Use' and 'Certified or Qualified' EHR (22-page PDF; About PDFs)
Association of Medical Directors of Information Systems "Meaningful Use" Web Site