'Meaningful Use' Stage 1 Must Be Evaluated Before Stage 2 Is Finalized, Comments Say

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“Meaningful use” criteria for Stage 2 should not be finalized until Stage 1 has been fully implemented and analyzed for successes and failures, hospital and provider organizations said in public comments to the Office of the National Coordinator for Health Information Technology on possible objectives for the second phase of the electronic health record incentive program.

Providers and health information technology vendors need time to implement the changes called for in Stage 1 of the Medicare and Medicaid meaningful use incentive programs before moving on to implementing Stage 1 requirements, the American Hospital Association, Federation of American Hospitals, American Medical Association, and Premier Healthcare Alliance said.

The comments--which were due Feb. 25 to ONC--were in response to preliminary Stage 2 objectives developed by ONC's HIT Policy Committee workgroup on meaningful use. The comments echoed those submitted to ONC Feb. 21 by the College of Healthcare Information Management Executives that recommended Stage 2 of meaningful use be delayed.

“Successful completion of Stage 1 for the majority of providers and thorough completion analysis of its impact are necessary before the adoption of additional objectives and more stringent measures,” the American Hospital Association said in its letter.

According to comments from the Federation of American Hospitals, there is already early evidence that the current staging of the program should be rethought and that there should be additional time for providers to meet the “high bar” set for Stage 1.

AHA recommended that Stage 2 of meaningful use not start until at least 75 percent of all eligible hospitals and physicians have successfully reached Stage 1, and not before 2014.

Incentive payments for adoption of certified electronic health record technology are federally funded under the Health Information Technology for Economic and Clinical Health (HITECH) Act provisions of the American Recovery and Reinvestment Act.

No New Objectives.

FAH recommended that to relieve the burden on providers of achieving meaningful use, Stage 2 of the programs should not have any new objectives.

The Centers for Medicare & Medicaid Services could instead comply with the requirements of HITECH by making the Stage 1 optional criteria mandatory, and increasing the use thresholds, FAH said.

CMS is responsible for developing the regulations for the Medicare and Medicaid EHR incentive program.

The workgroup has recommended some of the changes to make optional objectives mandatory and increasing use thresholds for Stage 2 compliance.

These changes could preserve some flexibility in the requirements for physicians and hospitals, Premier said.

One solution to the timeline challenges cited in the comments could be to require only a 90-day attestation period for the first year of each new stage of meaningful use, both AHA and FAH recommended. For Stage 2, the current attestation period is a full year.

The American Health Information Management Association also urged the HIT Policy Committee to consider other regulatory requirements providers must meet by 2013, such as requirements for ICD-10 conversion, electronic prescribing, and health reform mandates.

AMA Calls for Flexibility.

The AMA and other medical associations submitted a letter with comments expressing concern with “pushing too many requirements into meaningful use.”

Small physician practices already must make a bigger leap than most other provider types to achieve meaningful use, and physician organizations are concerned that the preliminary Stage 2 criteria could be too burdensome, the letter said.

According to the AMA letter, to maximize physician participation in the Medicare and Medicaid EHR incentive programs, ONC and CMS should:

• survey physicians who elected to participate and those who elected not to participate during Stage 1 of the incentive program, and identify barriers to and solutions for physician participation prior to moving to Stage 2;

• amend the requirements so that a physician can opt out of a measure if the measure has little relevance to the physician's routine practice;

• fully evaluate new requirements with regard to the expected impact of new objectives, the expected value of the new objectives, risks (both clinical and administrative), evidence of efficacy, administrative burden, costs to physicians, and technological standards of the new objectives; and

• avoid high thresholds for objectives that cannot be met due to the lack of available, well tested tools or bidirectional health information exchanges.

“The requirements for participation must be reasonable and attainable,” the letter concluded.

Consumer Advocates Support Stage 2 Criteria.

A collective comment letter from 25 of the nation's largest consumer groups lauded the proposed Stage 2 meaningful use criteria for the steps they take toward a “seamless integration of health information, coordination of care, and the ability to monitor improvements in outcomes and functional status.”

The comments also praised criteria aimed at helping patients and their caregivers interact with the health care system in more effective ways, such as secure patient messaging and patient access to electronic copies of health information.

The comments were organized by the National Partnership for Women & Families, which helps lead both the Consumer Partnership for e-Health and the Campaign for Better Care.

The comments were signed by AARP, the AFL-CIO, Consumers Union, Families USA, the National Alliance for Caregiving, National Family Caregivers Association, National Health Law Program, Service Employees International Union, and the Leadership Conference on Civil and Human Rights, among others.

The comments “strongly” supported making the optional criteria from Stage 1 mandatory, strengthening criteria for medication reconciliation and electronic prescribing, and emphasizing criteria that call for patient engagement in health care.

The letter also recommended that ONC and CMS pay particular attention to criteria that would encourage bi-directional health information exchange.

By Genevieve Douglas

The comment letter from AHA is available at http://www.aha.org/aha/letter/2011/110225-cl-meaningful-use-stage2.pdf.

The comment letter from FAH is available at http://www.fah.org/fahCMS/Documents/On%20The%20Record/Public%20Comments/2011/ONC_ltr_re_Stage_2_Meaningful_Use.pdf.

The comment letter from Premier is available at http://www.premierinc.com/about/advocacy/issues/10/hit/Premier-Comments-HIT-Stage2and3.pdf.

The comment letter from the consumer coalition is available at http://www.nationalpartnership.org/site/DocServer/CPeHCBC_RFCLetter_FINAL.pdf?docID=8301.

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