The Medical Group Management Association is calling for extensive reworking of the Stage 1 criteria for meaningful use of electronic health records, and to extend the Stage 1 period through 2013. Under the proposed meaningful use rule, Stage 2 criteria would start in 2013.

"It is critical that CMS and ONC carefully reconsider the proposed meaningful use definition and program requirements before crafting a final rule," the Englewood, Colo.-based association stated in its comment letter to federal officials. "We believe it is imperative to remember that the intent of ARRA was to provide a practical and achievable glide path to enable large numbers of physicians and other providers to adopt EHRs. We do not believe that the legislation anticipated the onerous nature of the proposed meaningful use criteria nor the expected high cost and decreased physician productivity associated with participation in this incentive program."

MGMA is asking the Centers for Medicare and Medicaid Services to request legislation to extend Stage 1 to 2013. "Stage 2 of the program could begin in 2014, and 2016 could be the start year for Stage 3 of the program. Penalties would not begin until 2016 under this recommended approach. This would yield additional and necessary time for the software to be developed, certified by the vendors, and implemented and tested in physician practices."

The association also recommends eliminating a number of meaningful use objectives and measures from Stage 1. These would include:

* Checking insurance eligibility electronically for at least 80 percent of all patients,

* Filing 80 percent of all claims electronically,

* Providing timely access to patients' health information for at least 10 percent of patients,

* Performing one test of the EHR's capacity to electronically exchange key clinical information,

* Performing medication reconciliation,

* Testing EHR capacity to submit electronic data to immunization registries and syndromic surveillance data to public health agencies, and

* Conducting or reviewing a security risk analysis.

MGMA also joins virtually every major provider association that has submitted comments in asking for a modification of the definition of "hospital-based provider" to enable more physicians to qualify for meaningful use incentives.

In a media conference call today announcing stimulus-funded grants for state-level health information exchange, Health and Human Services Secretary Kathleen Sebelius briefly addressed industry concerns over the proposed meaningful use criteria. The department believes it has struck an appropriate balance with the proposed criteria, she said, but feedback will be evaluated before the final rule comes out.

David Blumenthal, M.D., national coordinator for health information exchange, added: "We're trying to get physicians on the escalator for meaningful use and we want to get the first steps on the right level."

Full text of MGMA's comment letter is available at

--Joseph Goedert

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