On May 20, the Centers for Medicare and Medicaid Services (CMS) allowed providers another year to remain at Stage 1 of Meaningful Use, and the 2011 edition of CEHRT may be used for 2014. In addition, 2017 was confirmed as the start date for Stage 3. For some, unlike the ICD-10 delay, this postponement, confirmation and proposed rulemaking comes as no surprise.
Meaningful Use standards raise a drum beat of concerns. As I mentioned in my previous Meaningful Use blog, Dr Lipika Samai reported in JAMA Internal Medicine no correlation of Meaningful Use and improved quality measures. Remember, one of the reasons for this expensive and arduous task was to improve the quality of care.
On April 30, Clinical Innovation And Technology weighed in with concerns that patient safety is adversely affected by the adoption of current Meaningful Use standards, saying, “Many organizations are starting to question whether the pace of Meaningful Use (MU) is negatively impacting patient safety.”
In April, Emergency Care Research Institute (ECRI) identified Data Integrity Failures with Health Information Systems as the top patient safety concern for healthcare organizations in 2014. ECRI reported the following as potential sources of data compromise:
- Data entry errors;
- Missing or delayed data delivery;
- Inappropriate use of default values;
- Copy and paste of older information into new reports;
- Parallel paper electronic systems; and
- Mismapping of medical device data to the wrong patient.
Preserving data integrity, according to ECRI, starts with “assessing the clinical workflow to understand how the data is, or will be, used by frontline staff.”
The quality and safety concerns have not been unnoticed by CMS. Earlier this year the Office of the National Coordinator for Health Information Technology (ONC) produced toolkits to address the safety concerns. Titled “Safety Assurance Factors for EHR Resilience,” the SAFER initiative provides nine toolkits divided into three subsets - foundational, infrastructure and clinical process guides.
The AMA weighs in
With these substantial concerns as the backdrop, on May 8, Dr. James L. Madara, Executive Vice President and Chief Executive Officer for the AMA, sent a letter to CMS Administrator Marilyn B. Tavernner and Dr. Karen DeSalvo, the National Coordinator for Health Information.
The document clearly supports the adoption of electronic health records and information technology in healthcare, identifying their potential for improving quality and efficiency of care. The letter expressly states that the existing Meaningful Use program and many of the currently certified EHRs “stand in the way of these goals."
The AMA details specific changes for all three stages of Meaningful Use. The first is that the Physician Quality Reporting System (PQRS) should align with the quality component of Meaningful Use. Also recommended are that new mandates should be evidence-based, requirements should be tied to testing and high performance standards and implementation guides, and cost considerations should be part of mandate construction and selection.
The letter closes with the invitation to refocus on interoperability, synthesizing data into information for the clinician, openness to emerging technologies and real-world testing of IT products.
With their letter, the AMA is asking for substantially more than the CMS stage I extension announced May 20. The AMA letter is unambiguous, calling for “…achieving true interoperability that is deployed in a fashion that requires minimal user intervention. We believe ONC should focus less on what specific data points are exchanged, and more on identifying and coordinating the standards needed to exchange information.”
It will be interesting to watch responses to the AMA letter. I suspect we will hear reflex comments from the docs-don’t-like-change crowd. That view is not sustainable, as physician commitment to true Meaningful Use of information technology is critical for making EHR work for providers and patients.
Balancing act for the CMS
Consideration of the CMS response to the AMA letter should be tempered by the awareness of political forces flooding Health and Human Services. CMS must manage a dynamically evolving process where actions based on clinically reasoned judgments may morph into partisan food fights.
Despite this, I am optimistic. I am seeing dialogue everywhere among stakeholders, clinicians, vendors, administrators and agencies. Something good always comes from this environment.