The American Medical Informatics Association has proposed a radical change to the way CMS measures how well providers are using health IT to improve patient care.

In a comment letter to the Centers for Medicare and Medicaid Services, AMIA recommended that the agency replace existing EHR measurement-reporting requirements with an activities-based approach that would allow hospitals to demonstrate how they are using health IT to improve care for “their specific patient populations and priorities.”

AMIA was responding to CMS’ proposed FY2019 Hospital Inpatient Prospective Payment System rule, which the agency released in April.

Drop MU reporting

The proposed CMS rule for the Electronic Health Records Incentive Program, which now is called the Promoting Interoperability Program, would continue a 90-day EHR reporting period through 2020 but include fewer required measures for hospitals to report on.

“Meaningful use has served as a valuable vehicle to help digitize care delivery in the United States and thereby enable informatics-driven improvements in patient safety and clinical care,” says Peter Embi, Chair of AMIA and President and CEO at the Regenstrief Institute. “But now is the time to think differently about how this program should evolve to meet the rapidly-changing and often challenging environment of care delivery.”

CMS did not respond to a request for comment on the AMIA's proposals.

According to the AMIA, a review of recent literature indicates incentives from the meaningful use program significantly accelerated EHR adoption and improved the quality and safety of patient care. But as the EHR program moved beyond Stages 1 and 2, became more complex and financial incentives decreased, clinician satisfaction with the program fell.


Doug Fridsma, MD
Doug Fridsma, MD

“While AMIA has championed federal efforts to digitize care delivery through incentive payments, increasingly we have grown weary of prescriptive requirements for clinicians and a lack of resources for the Federal Health IT Certification Program, which provides the underpinnings of the EHR program,” the organization notes.

Focus on the home

Meanwhile, a prominent attorney and former official at the Health Care Financing Administration, the precursor to CMS, also has thoughts about how the agency could improve the measurement process for the EHR program.

Bruce Merlin Fried, an attorney in the healthcare group of the law firm Dentons US in Washington, D.C., likes a provision in the proposed Hospital Inpatient Prospective Payment System rule requiring clinicians to use EHRs certified to the 2015 meaningful use standards because this would support interoperability.

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But CMS is not paying enough attention to moving toward a “hospital- at-home” care strategy that emphasizes in-home nurse visits as well as the use of remote patient-monitoring devices. Focusing only on inpatient care will not reduce readmissions, Fried contends.

The bottom line is that “health IT facilitates better care but is not an end unto itself,” says Doug Fridsma, M.D., President and CEO at AMIA. “By enabling hospitals to demonstrate how they are leveraging clinical informatics, data analytics and other such tools to address priority patient populations, CMS can provide the regulatory flexibility these tools need to be successful.”

AMIA’s complete comments to CMS are available here.

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