AMA to CMS: Critical Changes Needed Before Moving to Meaningful Use Stage 3


The American Medical Association today called on the Centers for Medicare and Medicaid Services to address the challenges physicians are facing with the Meaningful Use program.


Chicago — The American Medical Association (AMA) today called on the Centers for Medicare and Medicaid Services (CMS) to address the challenges physicians are facing with the Meaningful Use program before moving on to the next stage. In a comment letter


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from AMA Chief Executive Officer and EVP James L. Madara, MD, the AMA recommended the program focus on patient safety, privacy and security, interoperability and how we can promote rather than hinder innovation.

“As we’ve said many times, the Meaningful Use program is not meaningful in its current form and is not helping physicians use electronic health records in a way that facilitates the best care coordination, increases efficiency or improves the quality of care for patients,” said AMA President-elect Steven J. Stack, MD. “We cannot ignore the current problems and barriers that exist with the program. The recommendations we provided address the significant challenges facing physicians, patients and vendors, and, if adopted, will lead to higher quality, cost effective care and increased innovation.”

Despite the fact that more than 80 percent of physicians are now using electronic health records (EHRs), less than 10 percent of eligible professionals were able to attest for Stage 2 Meaningful Use in 2014. The AMA recently supportedmany of CMS’ proposed modifications for 2015-2017 that could address some of measures that are the most challenging for physicians. However, it will take time for those modifications to take effect, which is one of the reasons why the AMA is calling on CMS to assess the impact of the proposed changes before moving forward with Stage 3.

The draft Stage 3 regulations were also drafted before CMS had the opportunity to assess the structure, requirements and impact of the new Merit-Based Incentive Payment Systems (MIPS). The MIPS program, which was created by the recent landmark legislation to reform Medicare, requires significant changes to the physician quality reporting programs, including Meaningful Use. These enhancements will transform Meaningful Use from a stand-alone program to one component of a larger reporting system, which will require alignment, resources and more regulations. Therefore the success of MIPS hinges on the success of Meaningful Use, which means more physicians must continue to participate and have access to the appropriate tools needed to move to an outcomes-based system.

Additionally, as evidenced in a recent Office of the National Coordinator for Health IT (ONC) report on data blocking, many health IT systems obstruct interoperability through excessive vendor fees or technical limitations that hinder physicians’ ability to meet Stage 2 of the Meaningful Use program. It also keeps the program from meeting its intended goal of facilitating coordination and helping improve the quality of care. Without focusing on the cornerstone issuesintegral to interoperability and quality improvement, the Meaningful Use program will never be truly meaningful.

The AMA is working to address interoperability challenges as a founding member of the Healtheway

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, which aim to resolve interoperability issues such as patient matching and information exchange rules.

Should the administration decides to proceed with moving to Stage 3 in 2018, the AMA has proposed a number of recommendations for improvements including:

  • Making 2017 a transitional year to alleviate many of the concerns both vendors and providers have regarding program updates, system changes and reengineering workflows
  • Implementing a reporting period that is less than a full year, to accommodate many unforeseen system disruptions that can occur outside the physician’s control
  • Consulting physicians and vendors before removing or adding measures
  • Heavily modifying the proposed objectives to align with the needs of medical specialists
  • Allowing quality measures reported to clinical registries to count for Meaningful Use quality reporting requirements

The AMA also sent a comment letter to CMS and ONC today regarding the proposed 2015 Edition Health Information Technology (Health IT) Certification Criteria. Among other things, the letter highlighted the AMA’s concern for the aggressive short timeframe that health IT vendors will have to produce highly-usable, interoperable, and safe technologies prior to 2018. For more information on that letter, please click here


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Our collaboration with the administration, policymakers, vendors, patient groups and other stakeholders to improve the Meaningful Use and EHR Certification programs is part of our ongoing efforts to shape a better health care system for all Americans. We are committed to supporting policies at every level of government that improve patient health, enhance access to affordable, quality care and that protect the privacy and trusted interactions patients have with physicians.

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