"In addition, hospitals have not yet had experience with Stage 2, given that the full set of final rules and specifications were just released last fall and no products to support Stage 2 are currently available."
American Medical Association Board Chair Steven J. Stack, MD, in the association's formal comments, reiterated a "continuing concern that the meaningful use program is moving forward without a comprehensive evaluation of previous stages to resolve existing problems. A full evaluation of past stages and more flexible program requirements will help physicians in different specialties and practice arrangements successfully adopt and use EHRs."
The American College of Physicians in its letter to ONC said Stage 3 measures need to be focused on measuring patient outcomes rather than on a growing collection of "functional measures." ACP said the proposed Stage 3 measures are nearly identical to those in previous stages.
"Stage 3 of Meaningful Use should encourage patients and practices to innovate, discovering creative ways to use the certified EHR technology they worked so hard to implement in Stages 1 and 2 and determining what has the greatest beneficial impact on the healthcare quality and value for patients, families and communities," said Michael H. Zaroukian, MD, chair of ACP's Medical Informatics Committee and author of ACP's letter.
"A number of the proposed Stage 3 measures necessitate significant increases in clinical documentation, involve new and potentially complex workflows, are likely to be difficult for many eligible professionals to understand and implement, or depend on technologies that are not yet widely deployed or shown to be usable in busy practices."