The nations largest physician organization is calling on the Centers for Medicare and Medicaid Services to fix the problems with what it calls the troubled Meaningful Use program before moving on to Stage 3.
In a Dec. 15 letter to Acting CMS Administrator Andrew Slavitt and National Coordinator for Health IT Karen DeSalvo, M.D., the American Medical Association submitted a set of recommendations with proposed revisions to the final Stage 3 rule released in October.
The AMA has raised substantial concerns about the effect of the MU program on the practice of medicine and the innovation of technology. Yet, Stage 3, as currently drafted, continues to restrict innovations in technology for patients and physicians and creates barriers in moving to the new Merit-Based Incentive Payment System (MIPS) and alternative payment models (APMs), states the letter.
AMAs vision for a revised Stage 3 is to address the current challenges with electronic health records and to provide a glide path towards MIPS and APMs. The group argues that the landscape has changed significantly since CMS originally issued its proposed Stage 3 rule. For instance, Congress in April passed the Medicare Access and CHIP Reauthorization of 2015 (MACRA), which adopted a new physician payment framework based on quality and value.
Program flexibility is the key factor in improving the Meaningful Use program, ensuring that Stage 3 objectives can align with advanced payment models, according to AMA. New payment systems will not work if physicians fail for missing just one of numerous requirements or are held accountable for technological failures outside of their control.
To address these challenges, AMA recommends the following overarching changes that it believes CMS should adopt immediately for Stage 3: Provide flexibility and eliminate a pass-fail program design; allow for multiple methods/paths to achieve desired end goals; remove threshold requirements for measures outside of the physicians control; re-orient measures away from process-based tasks to highlight goals that are useful to patients and physicians; encourage new technology functions to be the focus of certification rather than placing requirements on physicians and patients that may not yet be feasible; and support the reuse of data to reduce the burden on documentation.
For its part, the College of Healthcare Information Management Executives, representing CIOs and other senior health IT leaders, is urging CMS to delay the start of Stage 3 until at least 2019. CHIME sent a Dec. 14 letter to the agency arguing that Stage 3 should begin no earlier than 2019and only after 75 percent of all eligible providers have met Stage 2 requirements. Likewise, the American Hospital Association has called on CMS to postpone the required start of Stage 3 until a date no sooner than 2019. In addition, AHA recommended that the agency refrain from increasing EHR Incentive Program complexity until the vast majority of eligible providers have attained the current stage. Specifically, AHA advised that providers not be required to begin Stage 3 until at least 75 percent of eligible hospitals and professionals have met Stage 2.
While AHA and CHIME are calling for a delay in Stage 3, the Healthcare Information and Management Systems Society sent a Dec. 15 letter to CMS indicating that it does not want any changes to the final rule that might jeopardize its planned start in 2018.
HIMSS supports the 27 months provided for Stage 3 implementation from the publication of these Final Rules and the beginning of the 2018 reporting year, states the letter. However, since these Final Rules offer a comment period, HIMSS requests that any changes made to these Rules be made and published by February 29, 2016, so that providers and developers have as much time as possible to prepare for the optional year start of Stage 3 in 2017 as well as the 2018 reporting year.
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