Partial adoption of meaningful use of health IT should result in the receiving of partial fiscal incentives, wrote Ted Epperly, MD, board chair of the American Academy of Family Physicians (AAFP), in a letter to Charlene M. Frizzera, acting administrator for the Centers for Medicare & Medicaid Services (CMS).
“This new set of ‘meaningful use’ regulations shares a similar vision and objectives with AAFP policy and we are excited about the potential health IT progress made possible with these regulations,” wrote Epperly. “However, we believe that certain aspects in the details of these regulations are unworkable, excessive or redundant and will actually impede on the very goals of the legislation."
In the letter, sent on Feb. 26, Epperly made the following recommendations on behalf of the 94,700 U.S. physicians and medical students that AAFP represents “to strengthen and improve the meaningful use regulations."
Increase Participation through Partial Incentives: The AAFP said it "strongly believes" that offering a partial incentive for partial meaningful use will vastly increase the number of eligible providers who will make the attempt to become meaningful users of health IT. According to Epperly, the AAFP does not want to discourage practices who cannot achieve 100 percent of the requirements from using, improving or implementing EHRs if they won't receive anything for less.
Consider Parity between Medicare Fee-for-Service and Medicaid Program’s First Year Requirements: Consideration should be given to create parity for the first year between the two programs, allowing physicians in small and medium sized medical practices to receive incentive payment according to Medicaid requirements for either program, with attestation of meaningful use a requirement for payment in the second year, the letter stated.
Increase Achievement of Meaningful Use through Focused Reporting: “We strongly believe that efforts and resources in the practice need to be focused on the transformation of their practice and achieving high quality care-not on tracking denominators for process measures,” wrote Epperly. “We strongly recommend that those meaningful use measures be changed from a percentage to recording of absolute counts.”
Allow Eligible Providers to Devote Resources to Outcomes Reporting and Actual Meaningful Use: Epperly said that if it is “absolutely necessary” to report numerators and denominators for IT functionality measures, then AAFP recommends that shorter reporting periods be used (For example: 30 days).
Ensure Incentives for Team-Based Care: The AAFP recommended that CMS define “satisfied” in relation to the meaningful use objectives as explicitly not requiring the eligible provider to actually perform the task but rather to be responsible for ensuring its completion. “This is critical to patient-centered care via a team-based approach to care, which is fundamental to helping address the issues of primary care shortages and healthcare costs,” Epperly wrote.
Do Not Exclude Primary Care Physicians in Hospital Organizations: According to the letter, the AAFP recommended that any physician or practice that purchases a certified EMR technology be eligible for incentives under Medicare and Medicaid since the AAFP is concerned that the potential for family physicians who have a practice and are part of a larger hospital-based organization will be excluded from the definition of eligible provider.
“CMS should significantly modify the proposed rule to ensure participation by the majority of eligible physicians so that we can continue to transform our healthcare system,” concluded Epperly.