Eligible professionals should be required only to attest to meeting at least five measures to receive first-year incentive payments for meaningful use of electronic health records, according to 96 physician associations, including the American Medical Association and 48 of its societies.

In a comment letter on the proposed meaningful use criteria, the groups also recommended physicians in the first payment year be required to only attest that, "to the best of their ability," they are entering required data elements for quality measure reporting.

Further, the organizations want the proposed use of numerator and denominator data eliminated in order to establish that an objective has been met. "We are very concerned that CMS' proposal to use numerators and denominators could significantly jeopardize physicians' ability to meet the incentive program requirements," according to the comment letter. "The proposed use of numerators and denominators will require significant manual calculations on the part of physicians since there are no automated reports that can capture all of the orders, lists, results, conditions and other health related information that must be tabulated. Percentage threshold reporting should only be required when the EHR has the ability to automatically and easily calculate all metrics that are required to be reported."

Other recommendations include:

* The need for small physician practice representation on the Health IT Policy Committee and its workgroups;

* Creation of a mechanism for evaluating the progression of meaningful use objectives and measures, as the costs of adoption, before moving from Stage 1 to Stage 2; and

* The ability to give physicians feedback on their performance so they will know if they are meeting criteria for meaningful use incentives.

Some of the other associations signing the comment letter include the American Academy of Family Physicians, American College of Physicians, American Osteopathic Association, American Psychiatric Association, Medical Group Management Association, and Society for Hospital Medicine. The letter is available here.

--Joseph Goedert

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