The following is a letter from organizations to HHS on January 14, 2016.
The Honorable Sylvia Burwell
Secretary
Department of Health and Human Services
200 Independence Ave., S.W.
Washington, DC 20201
Dear Secretary Burwell:
On behalf of the undersigned organizations, we are writing to express our concerns with the Meaningful Use (MU) program and the current state of electronic health records (EHRs). We recognize that the MU program has successfully driven the adoption of EHRs, with over 80 percent of hospitals and physicians now using these systems. We must now turn our attention to ensuring that all of the practices in our respective communities have high-functioning technology to achieve interoperability across all care settings. Yet, with the release of Stage 3, we fear the current trajectory of the MU program will hinder efforts to move forward.
Our collective experience with MU has shown that the current measures and pass-fail approach deter participation. In particular, the MU program has diverted clinician, staff, and other resources away from activities with greater patient benefit and has forced technology to develop in a way that limits innovation. The MU Modifications rule addressed these concerns by reducing some of the pressure physicians and hospitals face in trying to meet MU program requirements. These modifications, however, should not be looked at as a cure but as temporary relief while we work to restructure the MU program to fit future care needs and focus on improving interoperability and usability.
Despite the written comments of numerous stakeholders and data on provider experience with Stage 2 of the program, Stage 3 continues to press forward with the current, ineffectual Meaningful Use structure—the one-size-fits-all approach that lacks accommodations for the different needs of our practices and our patients. The Stage 3 final rule, like its predecessor rules, is too focused on pass-fail requirements and lacks emphasis on outcomes. By maintaining this flawed structure, we do not believe Stage 3 will support movement towards more innovative care models or encourage continued participation.
Stage 3 also fails to prioritize foundational issues to improve interoperability, which is imperative for our medical communities to function at their highest levels. By using MU as an enforcement tool, there has been little improvement in data exchange. Many in our communities are facing excessive costs to purchase EHR interfaces and upgrades, which only support limited interoperability. Patient medical information is also shoehorned into a format that was designed for MU measures, and not in a way that accommodates the needs of physicians and patients. Addressing these issues must be a priority, but what is required in the Stage 3 rule limits progress while diverting needed resources. Regrettably, we believe the Stage 3 final rule maintains the same problematic measures in Stage 2 and will not put the nation on a path to reach these goals.
Lastly, the MU program has been the driving factor behind the design of EHR technology. Health IT vendors routinely state that meeting MU requirements monopolizes most of their development and testing time and that many of the upgrades or features most requested by their customers are put on the backburner until the complex process of certifying for MU takes place. We believe Stage 2 EHR design requirements have been a fundamental drag on interoperability and that Stage 3 will worsen these problems.
Given the above concerns, we urge you to reconsider Stage 3 and refocus the Administration’s efforts on the infrastructure needed to promote adoption, enhance interoperability and improve usability. We are of the collective mindset that this is an opportunity to improve the current trajectory of EHRs and the MU program to best support technical innovations and outcomes-based care. Navigating the digital landscape is a constant learning process. As health care providers who are at the forefront of incorporating these digital health tools, we appreciate the opportunity to share our thoughts on a path forward for the MU program.
Sincerely,
Advocate Health Care, IL
Aurora Health Care, WI
Austin Regional Clinic, TX
Baptist Health, KY
Baylor Scott & White, TX
Beth Israel Deaconess Medical Center, MA
Billings Clinic, MT
Boston Children’s Hospital, MA
Collaborative Health Partners of Virginia and Central Virginia Family Physicians, VA Confluence Health, WA
Cornerstone Healthcare, NC
Crystal Run Healthcare, NY
Dreyer Clinic, IL
Eastern Virginia Medical School Medical Group, VA
EmCare, TX
Emory Healthcare, GA
Fairview Health Services, MN
Geisinger Health System, PA
Henry Ford Health System, MI
InterMed, ME
Intermountain Healthcare, UT
The Iowa Clinic, IA
Marshfield Clinic Health System, WI
Mount Auburn IPA, MA
Partners HealthCare, MA
TEAMHealth, Inc., TN
Trinity Health—New England, CT
UMass Memorial Health Care, MA
University of South Florida Health, FL
Vanderbilt University Medical Center, TN
Weill Cornell Medicine, NY