MU Stage 2 Requirements 'Overly Burdensome,' Say AHA, AMA

The American Medical Association and the American Hospital Association say they support widespread adoption of electronic health records, but are asking for flexibility to meet the program's requirements.

With Meaningful Use Stage 2 implementation deadlines looming in the next few months, the nation's two largest provider associations this week asked the federal government for "flexibility" to meet the program's "all-or-nothing" requirements.

In a joint letter to Health and Human Services Secretary Kathleen Sebelius, the American Medical Association and the American Hospital Association pledged their support for the widespread adoption of electronic health records.

"However, we believe that the best way to move the program forward and ensure that no providers, particularly small and rural ones, are left behind is to realign the Meaningful Use Program's current requirements to ensure a safe, orderly transition to Stage 2," AHA President/CEO Rich Umbdenstock and AMA CEO James. L Madara, MD, said in their letter.

Stage 2 implementation for hospitals begins on Oct. 1, the first day of the federal fiscal year. For physicians, Stage 2 begins on Jan. 1, 2014. The AHA and the AMA said in their joint letter, however, that the implementation dates have placed EHR vendors on an overly aggressive deadline to provide technical support for more than 500,000 hospitals and physicians.

"Our members, and the vendors they work with, report growing concerns that the rapidly approaching start date for Stage 2 is on a trajectory that will not provide enough time or adequate flexibility for a safe and orderly transition unless certain changes are made," the letter states.

"As of July 17, the official federal list of certified vendor products shows only nine complete 2014 Edition certified EHRs for the inpatient setting, produced by only six vendors. By comparison, the list shows 313 complete 2011 Edition certified inpatient EHRs. On the ambulatory side, only 11 complete 2014 Edition certified EHRs are listed, while about 1,300 were certified for 2011."

Umbdenstock and Madara said they've also heard from members that vendors are delaying the delivery of systems updates and that providers who have not installed EHRs will be at the end of the line and won't get delivery for as long as 18 months.

"Of course, receiving an upgrade is only the first step in making the transition to the 2014 Edition and meeting the Meaningful Use requirements. It is reasonable to expect that a provider will need up to a year after receiving a technology upgrade to make all of the necessary changes to meet the program requirements," the letter states.

Umbdenstock and Madara said the aggressive Stage 2 deadline is also complicated by the demands for transitioning to ICD-10 by Oct. 1. 2014. "Furthermore, some providers are reporting significant challenges with the usability of their current certified EHRs, a situation that will be exacerbated as vendors channel their efforts to managing a nation-wide transition to the 2014 Edition," the letter stated.

The AHA and AMA said they were also concerned that the existing deadlines would "exacerbate the digital divide" that now exists between small and rural hospitals and physician groups and their larger urban counterparts.

"Given this complexity and level of difficulty, a program with an 'all-or-nothing approach'—in which failure to meet any individual part of an objective, or missing a threshold by a small amount, leads to overall failure in meeting Meaningful Use—is overly burdensome," the letter says. "This seems especially true given that any provider failing to successfully transition to Stage 2 will not only miss an incentive payment but also receive a future payment penalty. Providers who fail to enter the program for the first time in 2014 will also receive future payment penalties."

Umbdenstock and Madara offered four recommendations that they said could be implemented without changing the law.

• Allow providers at Stage 1 to meet the requirements using either the 2011 certified Edition EHR, or the 2014 certified Edition EHR. This will allow more time for vendors to complete upgrades, allowing advanced providers to move ahead to Stage 2, while holding harmless those remaining or entering the program at Stage 1.
• Establish a 90-day reporting period for the first year of each new stage of Meaningful Use for all providers, similar to what was done for Stage 1. This will allow upgrades to be spread out over time, rather than being clustered on certain dates.
• Offer greater flexibility to providers in meeting Stage 2 to ameliorate the "all-or-nothing" problem, and recognize that the level of change in Stage 2 will take time to accomplish.
• Extend each stage of Meaningful Use to no less than three years for all providers. This change recognizes that vendors need time to develop usable and safe upgrades, and providers need time to implement systems and optimize their use before undertaking yet another upgrade.