Proposed criteria deemed too difficult for physicians to achieve success in earning payments
The good news was that the American Recovery and Reinvestment Act of 2009 promised you incentives for adopting an electronic health records (EHR) system. But troubling news followed when the Centers for Medicare & Medicaid Services (CMS) said to qualify as a meaningful user of EHR, you would need to meet all 25 Stage 1 proposed criteria in in 2011.
The comment period on these criteria is now closed, but not before the AMA, 95 state and specialty medical societies and the Medical Group Management Association (MGMA) called for revisions.
“The AMA is supportive of the widespread adoption and meaningful use of EHRs by physicians, but the Stage 1 criteria proposed by CMS are too aggressive,” said Steven J. Stack, M.D., member of the AMA Board. “It could unreasonably punish physicians who undertake great efforts to achieve meaningful use of EHRs – only to be denied incentive payments due to overly complex and unattainable criteria.”
As proposed, a physician could devote numerous resources to complying in 2011 on the 25 objectives, but narrowly miss one and be disqualified for the incentive payment that year.
“Overall, the proposed reporting criteria require more flexibility,” Dr. Stack said.
The big concerns
As noted in its comments, the AMA wants CMS to:
- Remove the “all or nothing” approach and require physicians to meet five of the 25 proposed objectives and measures instead of all 25
- Eliminate the objectives and measures that don’t directly apply to EHR adoption, such as checking insurance eligibility electronically
- Revise the definition of meaningful use for certain hospital-based physicians to broaden eligibility for the federal incentive programs (see box below)
- Reduce the number of quality measure reporting requirements and allow physicians to identify only three clinically relevant measures
Those reporting requirements worry ISMA member Alan Snell, M.D., chief medical informatics officer for St. Vincent Health. Dr. Snell works with physicians in his hospital system on EHR adoption.
“The biggest concern is – even if physicians have EHRs – will they be able to meet meaningful use requirements to export information to agencies and registries?” he said.
“Doctors will need analytic capabilities with their EHRs to produce the detailed reports needed to meet quality and registry requirements.”
MGMA worries about productivity
MGMA conducted research that points to the need for changing practice operations to meet the 25 criteria. According to MGMA, respondents to its survey about the proposed requirements said the most difficult would be:
- That 80 percent of all patient requests for an electronic copy of their health information be fulfilled within 48 hours
- That 10 percent of all patients be given electronic access to their health information within 96 hours of the information being available
The organization, which claims to speak for 21,500 medical practices and 275,000 physicians, said that while it advocates for adoption of EHRs, the transition must begin by successfully aligning incentives with overall cost to the implementing entities.
CMS has indicated final objectives would come in “early spring.” ISMA Reports will alert you when that happens.
Find the proposed rule here.
Find fact sheets and other information at the HHS website.
New law may extend the EHR incentive to your work setting
New legislation extends the federal electronic health record (EHR) incentive and allows more physicians to potentially qualify as meaningful users.
As a result of the Continuing Extension Act of 2010, physicians who provide services in hospital-based outpatient clinics will fall under the definition of “incentive eligible,” a change that becomes as effective as other original provisions of the American Recovery and Reinvestment Act (ARRA).
The recent act, signed April 15, eliminated a restriction by removing the word “outpatient” in the description of a hospital-based setting.
ARRA’s original restriction read “whether inpatient or outpatient.” The thinking was that hospital-based physicians already benefit from their hospitals’ EHR systems.
The physician restriction now reads “inpatient or emergency room setting.” While excluding ED doctors, the incentive becomes available to physicians who practice in a hospital’s outpatient clinic or a facility on hospital premises.
Original – American Recovery and Reinvestment Act of 2009
Restriction: “whether inpatient or outpatient”
Change – Continuing Extension Act of 2010
Restriction: “inpatient or emergency room setting”