Providers Push for Slower Stage 3 MU Roll Out

The nation's leading hospital and physician associations offered variations on the same message this week when they replied to the federal government's request for comments on Stage 3 meaningful use implementation: We support what you're doing, but slow down!

The College of Healthcare Information Management Executives summed up the feelings of many physicians and hospital leaders when it asked the HIT Policy Committee and the Office of the National Coordinator for Health IT to "reconsider the speed and scale for achieving Stage 3 meaningful use objectives by 2016."

"We see no value in setting unrealistic performance thresholds or expectations before current evaluations of what we have accomplished have been undertaken," CHIME said in a letter to National Coordinator for HIT Farzad Mostashari, MD.

"[E]very desirable EHR-related objective cannot feasibly be met by 2016, nor do we see any value in attempting the rushed adoption of various EHR uses by that time. Instead, verifiable and continuous progress should be the goal."

Pam McNutt, CIO at Dallas-based Methodist Hospital System and member of CHIME's Policy Steering Committee, said in prepared remarks that the main message to regulators "is that we shouldn't look to cram everything into Stage 3. The modernization of America's healthcare system is a decade-long progression. We need to make sure that the HIT Policy Committee is looking at more than just the Stage 2 measures and objectives when making recommendations to HHS; that's why we strongly urged thorough evaluations of to-date accomplishments and progress."

The Federation of American Hospitals, representing more than 1,000 for-profit hospitals, suggested in its formal comments that ONC extend the current two-year roll out cycle for meaningful use stages by an additional year for Stage 2 and Stage 3, and future stages.

"We raise these concerns not to suggest that we should not move the Meaningful Use program forward, but rather that we take a judicious approach to Stage 3," FAH said in its letter.

"Providers are almost focused solely on being compliant with requirements, rather than optimizing the technology that has already been implemented. Meaningful Use is not, and cannot be, the sole focus of providers. Too many important areas are being neglected as a result—harmonization of eMeasures, population health, patient identification and matching, etc. We urge policymakers to stop regulating providers to the point that they simply do not have the time or bandwidth to use their (Certified EHR Technology) to improve care."

The American Hospital Association wrote in its formal comments that the ONC's proposal includes a "very ambitious" set of recommendations for Stage 3 that would make more than 40 changes to Stage 2 requirements.

"The AHA believes it is too soon to define the meaningful use requirements for Stage 3. As of September 2012, fewer than one-third of hospitals had met the Stage 1 requirements and received a Medicare incentive payment," Linda E. Fishman  AHA's senior vice president, public policy analysis and development, said in a letter to Mostashari.

"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."