Even as providers struggle to fulfill Stage 1 meaningful use requirements, conflicting waves of interest are already rising around the potential Stage 2 requirements, with consumer groups and medical societies urging the federal government in different directions regarding the rigor of the Stage 2 requirements, as officials at the Office of the National Coordinator for Health Information Technology (ONC) receive comments from interested parties around Stage 2 issues.
On the healthcare professional side, a coalition representing the American Medical Association and 38 other national medical societies and associations (including the Medical Group Management Association, plus a broad range of medical specialty societies) sent a letter on Feb. 25 to Joshua Seidman, Ph.D., at ONC, urging ONC to take a number of steps. The coalition’s letter stated that “Inflexible, overly ambitious incentive program requirements will only hinder health IT transitions underway today. Promoting greater flexibility to meet meaningful use requirements will help us achieve the desired outcome for the Medicare/Medicaid EHR incentives—accelerating the widespread use of technology to improve our nation’s health care delivery system,” the letter urged.
Among the specific steps the coalition urged ONC to take were the following:
- “The Centers for Medicare & Medicaid Services (CMS) and the ONC 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.”
- “Measures for meeting meaningful use should factor in appropriate use. Reasonable exclusions for many requirements should be included so that a physician can opt out of the measure if the measure has little relevance to the physician’s routine practice…”
- ONC and CMS should “thoroughly assess” the impact on efficacy of any new measures in the core set of Stage 2 measures, and should assess the potential of administrative burden and costs that would be added to physicians’ efforts in order to achieve meaningful use.
- “High thresholds should be avoided for objectives that cannot be met due to the lack of available, well-tested tools or bidirectional health information exchanges.”
- And, “Measures that require adherence from a party other than the physician should be removed (e.g., patient’s accessing patient portal, labs reporting test results).”
One of the key issues that the coalition identified in its letter around what its members considered overly burdensome requirements were those that have been mainly primary care-focused, with little relevance or benefit to specialist physicians, yet without what the coalition considers appropriate exclusion categories. “Eight of the 15 Stage 1 core measures and three of the 10 Stage 1 menu options do not include an exclusion category,” the Feb. 25 letter noted, adding that “We strongly recommend that many of the measures for Stage 2 include an exclusion option so that a physician can opt out of the measure if the measure has little relevance to the physician’s routine practice.”
Meanwhile, also on Feb. 25, a coalition called the Consumer Partnership for eHealth sent an equally strongly-worded, detailed letter to Dr. Seidman at ONC, focusing on the benefits to healthcare consumers of a very rigorous process in Stage 2 and stating that “We strongly support the transition of all ‘menu’ (optional) criteria from Stage 1 to ‘core’ (required) in Stage 2.” The Consumer Partnership is an umbrella coalition of 25 national consumer, senior, and organized labor groups, including the American Association of Retired Persons (AARP), Families USA, the National Consumers League, the AFL-CIO, and the Service Employees International Union (SEIU).
Among the numerous recommendations of the Consumer Partnership for eHealth were the following:
- With regard to the Stage 1 requirements around making patient health record information available to patients, the coalition urged ONC to increase the threshold for provider accountability for making their own personal health information available to patients.
- The coalition urged that ONC include an added new criterion “requiring providers to record a longitudinal care plan for patients with high-priority health conditions” into Stage 2. The coalitions letter stated that “Stage 2 meaningful use MUST begin addressing the need to track information longitudinally to enable measurement of improvement over time, and to ensure that the care plans reflect patient preferences, shared goals and agreed-upon action steps.”
- The coalition’s letter also urged an intensified focus on health information exchange, and on the recording of patient demographic information, in order to “use these demographics to produce stratified quality reports.”
It will be fascinating to see how officials at ONC and CMS balance out these competing agendas. What is particularly interesting is that, reading both coalitions’ letters at the same time, there isn’t inherently tremendous conflict between the two different groups on certain specifics; but overall, of course, the thrusts of the two letters are diametrically opposed in general outlook. The flexibility and “go-slow” approach advocated by the AMA and the other medical associations and specialty societies speak to an implementer’s view of meaningful use that is in stark contrast to the “keep the pressure on” perspective of the consumer alliance. Who can say which overall plan ONC and CMS will endorse? Only time—and more iterative discussions and interactions—will tell.
