The comment period for the Health IT Policy Committee’s stage 3 meaningful use recommendations passed this week. Several professional groups took the opportunity to express their concerns with the recommended list of policy changes.
The American Medical Association (AMA), the American Hospital Association (AHA) and the Federation of American Hospitals said in letters to the Office of the National Coordinator for Health IT that they want the agency to fund an external review of the effectiveness of the meaningful use regulations. This is because, as the AHA letters claims, many of the measures included in the proposed list are not based on evidence. Any regulatory changes should be made to achieve meaningful improvements in patient care, rather than simply require a particular technical function.
Health information exchange infrastructure is seen as a barrier to achieving several of the recommendations for stage 3. The proposed rules set a high bar for data exchange, mostly in transition of care, but the AMA, AHA and College of Health Information Management Executives (CHIME) said in their letters that such regulations should be contingent on the availability of HIE infrastructure. They point out that progress toward robust HIE and interoperable EHR systems has been slow in coming. Therefore it is unreasonable to require physicians to exchange information when the technical tools aren’t there.
Groups also said that requiring doctors to achieve 100% of the meaningful use rules is unreasonable. Both AMA and CHIME point out that physicians could meet the vast majority of program requirements but miss out on incentive payments due to non-compliance with a single measure. In their view providers who make good-faith efforts and meet that majority of the regulations should still be eligible for incentives.
The Society for Participatory Medicine (SPM) had praise for aspects of the proposed stage 3 rules. In its comment letter, the group agreed with the HIT Policy Committee’s own assessment that the rules “begin to transition from a setting-specific focus to a collaborative, patient- and family-centric approach.” The SPM letter lauds regulators for proposing a mechanism that could give patients the opportunity to correct misinformation in their records. Additionally, the group is in favor of proposed rules that would give patients access to their own records, but would like to see the time in which these records are made available shortened.