An “inappropriate definition" of meaningful use and “inefficient administration” of the Medicare and Medicaid EHR incentive programs will lead to failed implementation of the American Recovery and Reinvestment Act of 2009 (ARRA), resulting in the “needless squandering of resources and significant disruption” to the U.S. healthcare system, according to a letter written to David Blumenthal, MD, from the Medical Group Management Association (MGMA).
William F. Jessee, MD, president and CEO of MGMA, in a letter dated Nov. 12, wrote that the organization is “very concerned about the implementation process for the Medicare and Medicaid EHR incentive programs currently under development.”
Blumenthal, the national coordinator for health IT, and his office are responsible for dispensing funds issued for health IT in the ARRA, and also for establishing the definition of meaningful use.
In the letter, Jessee makes the following recommendations, among others:
- Avoid reliance on third party compliance: Several of the draft meaningful use criteria require, for example, the reporting of percentages of patients undergoing specific tests. MGMA said it is strongly encouraging ONC “not to impose arbitrary thresholds that physicians would have to meet for the reporting of these types of measures.”
- Selection of criteria already in widespread use: It is “critical” to avoid imposing criteria that do not have widespread experience in the small and rural clinical settings, according to MGMA.
- Selection of appropriate administrative criteria: The association said that administrative transactions currently outlined in the meaningful use matrix that physicians would have to report do not take into account the reality of current practice workflow or the inefficiency of the current standards themselves.
- Institute a pilot: Once the final rule is published, and well before to the 2011 program start date, MGMA suggested the government conduct a pilot with a small number of vendors and in a variety of physician practice settings to ensure that the process of demonstrating meaningful use is achievable and practical.
- Simplified physician attestation: The process for physicians to demonstrate that they have achieved meaningful use should be simple and flexible enough so that physicians in all types and sizes of practice can attest this to the government.
- Simplify the reporting process: Allowing practices of varying sophistication the ability to report the quality data utilizing various methodologies (ie, claims-based, data registries and summary clinical data transmitted directly via the EHR) would ensure that as broad a group of practices as possible would have the ability to move forward with adoption of HIT, successfully report quality measures and qualify for the incentives, MGMA said.
- Closely monitor provider and vendor progress.
Jessee concluded that association “strongly supports the objectives of the ARRA incentive programs,” but said that an “appropriate definition of meaningful use and program logistics must be developed,” or the government “runs the risk” of excluding a large percentage of physician practices from participation.