Dozens of Organizations Express Meaningful Use Concerns

Letters Urge Pause in Implementation of MU Stage Three

September 24, 2015 02:14 pm News Staff

The AAFP joined 40 other medical specialty organizations in asking HHS Secretary Sylvia Burwell and Shaun Donovan, director of the Office of Management and Budget, (OMB) to hit the "pause" button on the implementation of meaningful use (MU) stage three.

[Physician working at desk on computer]

In separate but identical Sept. 17 letters(3 page PDF) to the two federal executives, the organizations, including the AMA, the American Academy of Pediatrics, the American College of Physicians and the American Osteopathic Association, told Burwell and Donovan that physicians nationwide were "extremely concerned" with the current direction of the overall MU program.

The letters pointed out that even though 80 percent of physicians were utilizing electronic health records (EHRs), not even 10 percent had successfully participated in MU stage two.

The medical organizations described America's physicians as "extremely dismayed" by news that HHS' modifications rule( and the MU stage three rule (neither of which had been published in the Federal Register at the time this story posted) were being reviewed by the OMB.

Unfortunately, said the letter, software products currently available to physicians were created by vendors to comply with inflexible MU regulations and certification requirements. Those products -- described in the letter as "frequently unusable and administratively burdensome" -- continue to frustrate physicians.

Story Highlights
  • The AAFP and 40 other medical organizations have asked HHS and the Office of Management and Budget (OMB) to pause work on implementation of meaningful use (MU) stage three.
  • In separate letters to HHS and OMB, the organizations said that in a rush to satisfy earlier MU requirements, software vendors created burdensome products that frustrate physicians.
  • The letters urged the government to slow down on MU to better understand how to best implement important aspects of the Medicare Access and CHIP (Children's Health Insurance Plan) Reauthorization Act.

The organizations argued that if the stage three MU regulation were to be implemented now, vendors would continue to create software that would "lock in problematic technology" for years to come.

MU stage three "exacerbates problematic policies" of stage two, with its "one-size-fits-all objectives," said the letter.

Indeed, the organizations took their disappointment one step further when they pointed to MU stage three and called it a "drastic step backward" from the proposed improvements of the modifications rule.

Furthermore, they lamented the fact that stage three was "developed prior to and without consideration of" changes coming down the pike as a result of enactment of the Medicare Access and CHIP (Children's Health Insurance Plan) Reauthorization Act (MACRA).

The letter argued that the MU program would play an important role in the new Merit-based Incentive Payment System (MIPS),( as well as the development of alternative payment models (APMs).

"The administration should therefore pause MU stage three and re-evaluate the program in light of these pivotal changes to Medicare."

The organizations expressed confidence that a delay in stage three would not impede progress in the uptake and utilization of EHRs; rather, they suggested that a delay would serve to "move the program forward and drive innovation and adoption."

To that end, the letter urged the administration to quickly finalize the modifications rule, as well as integral pieces of the proposed 2015 Edition Certification Rule.(

Furthermore, the organizations asked that the administration

  • release a revised 2014 certified EHR edition,
  • provide updates to the testing and use of clinical and quality document standards,
  • adopt more stringent safety enhanced design requirements,
  • standardize application programming interfaces,
  • conduct "in-the-field" health IT surveillance, and
  • provide transparency and disclosure requirements.

"Physicians and patients should not have to wait until 2018 to see improvements to current technology," said the organizations. And, because the administration has delayed the release of program requirements as outlined in the modifications rule, an additional hardship exemption category must be established to cover "physicians who could not anticipate new program mandates so late into the year."

Lastly, noted the letter, pausing stage three now will give all parties an opportunity to "evaluate the environment" and implement changes outlined in the modifications rule.

"There are so many questions surrounding creation of MIPS and APMs that it is premature to proceed with MU stage three, especially since EHRs and MU will serve as a foundation for the success of these programs," said the organizations.

Moving forward with stage three at this time would "severely undermine" the ability of the health care system to support the implementation of the MACRA legislation, they concluded.

Related AAFP News Coverage
AAFP Fires Off Recommended Changes to 2016 Proposed Medicare Physician Fee Schedule

Additional Resource
CMS Fact Sheet(