The American College of Physicians in a comment letter to federal officials contends that early proposals for Stage 3 electronic health records meaningful use criteria fall short by expanding collection of EHR functional measures rather than moving providers toward measuring and improving patient outcomes.

That could cause providers to not accept Stage 3 as a worthwhile endeavor, the association believes. “We are deeply concerned that eligible professionals and eligible hospitals will perceive the time, energy, cost and effort required to understand and comply with the proposed Stage 3 measures to be so arduous and difficult to meet that they will be unwilling to strive to achieve them,” according to the comment letter. “We believe this problem will be amplified by what they interpret as a focus on accountability for increased documentation rather than improved outcomes.”

Some proposed measures could require new complex workflows, are difficult to understand, or dependent on technology not available or demonstrated to be usable, the ACP asserts. And other measures lack clear evidence of value to help improve care quality or satisfaction.

On the other hand, there are aspects of the proposals that ACP supports. They include more robust clinical decision support, making text-searchable electronic notes available quicker, having hospitals provide structured lab results to physicians, and timely hospital notification of significant events to a patient’s other providers.

The association’s comment letter is available here.

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