The American Medical Association in a 31-page letter to CMS Administrator Marilyn Tavenner lays out a litany of recommendations to save Stage 2 and ensure success of Stage 3 of the electronic health records meaningful use program.

“After three-and-a-half-years of provider participation, we are at a critical crossroad where we believe it is important and necessary to pause and fully assess what is working and what needs improvement before moving ahead to Stage 3 of the program,” the association contends.

The recommendations, many of which AMA has previously proposed, include:

* Remove the all-or-nothing attestation approach with adoption of a 50 percent threshold for incurring a penalty and a 75 percent threshold for earning an incentive for Stages 1 and 2. “At the very least,” make optional Stage 2 measures for view/download/transmit, transitions of care and secure messaging. “The single greatest barrier physicians face to date in meeting MU is the all-or-nothing approach of the program that results in a zero sum game,” AMA contends.

* Remove percentage thresholds for measures and the concept of menu vs. core measures in Stage 3. AMA advocates a single list of adequate measures that enable physicians to choose those that best meet their practice and patient mix. This also will mean “vendors would no longer need to tabulate whether a physician has met a measure, allowing them more time and resources to innovate and improve the physician EHR user experience.”

* Provide new measures to expand options for specialists in Stage 3 and require the meeting by physicians of no more than 10 measures under Stage 3.

* Provide hardship exemptions for all meaningful use stages. This includes exempting physicians who are successful in PQRS reporting from MU quality reporting requirements; expand “unforeseen circumstances” hardships; provide exemptions for hospitalists and physicians close to retirement; and continue exemptions for anesthesiologists, radiologists and pathologists.

* Improve quality reporting through better alignment with PQRS, increase public input for new e-clinical quality measures, continue to let physicians report on menu measures, eliminate measures no longer following the latest clinical evidence, and ensure registry participation and interoperability.

* Revamp EHR certification to focus solely on interoperability, quality measure reporting and privacy security; remove the requirement that only licensed medical professionals and credential medical assistants can enter orders; and adopt recommendations for user-centered design and well-developed data management principles.

The AMA also calls for physicians to not be penalized because of problems with meaningful use measures and standards, and specifically calls out the C-CDA patient information exchange standard as not being ready for prime time when the government adopted it, and still considered a draft standard for trial use.

The complete letter is available here; non-members must create an account but need not become AMA members.

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