EMR meaningful use standards need flexibility
■ Physicians are eager to embrace electronic medical records, but the implementation schedule demanded by proposed federal incentive requirements is too aggressive.
Posted April 5, 2010.
Physician adoption of electronic medical records has the potential to be one of the next great developments in medical practice. But, like any medical breakthrough, EMR adoption must be accomplished thoughtfully and correctly, not hastily.
The federal government has demonstrated that it is committed to promoting a paperless health system by offering financial incentives starting next year for physicians and hospitals that adopt certified EMR systems. Doctors appreciate this support and are ready to do their part. They realize that it is one thing for a practice simply to install an EMR and quite another for that practice to use the system in a way that can promote high-quality, safe and efficient patient care.
But the proposal by the Centers for Medicare & Medicaid Services for what signifies "meaningful use" asks too much of physician practices too quickly. Not every issue can lead to total agreement among almost 50 medical specialty organizations and nearly every state medical society. But these groups, the AMA among them, all have signed onto a recent letter urging significant revisions to how the government will decide who qualifies for the EMR incentives.
Consider the current landscape. The vast majority of practices consist of five physicians or fewer. To many doctors, concepts such as computerized physician order entry, structured and codified SIG, and EMR modules are relatively foreign terms. To expect small practices with minimal health information technology experience to embrace a relatively robust, fully featured EMR in a short time frame is a tall order.
By mandating that physicians' paperless systems meet all 25 meaningful use objectives and standards -- some of which don't even apply to EMR adoption -- by next year, CMS is taking too aggressive a timeline. Adding a requirement that practices use EMRs to report numerous clinical quality measures -- as many as 29 in some cases -- would make it all but impossible for some to make the grade.
Imagine a solo practice that spends more than $50,000 to implement a new paperless records system only to find that the "all-or-nothing" approach that CMS is proposing means that the practice won't recoup any of its investment that year. Now the physician and his or her staff are stuck with a system that might cost another $10,000 a year to maintain, as they struggle to cut their losses, trying to qualify for future bonuses before the amounts get smaller and eventually disappear.
Surely this inhibiting, zero-sum game is not what Congress intended when it approved tens of billions of dollars for Medicare and Medicaid EMR adoption bonuses. Some practices will decide that the incentives are just not worth the risk.
Fortunately, the CMS regulation is only a proposed rule. There is still time to change it before the final version comes out later this year.
The agency can take some major steps toward making implementation workable by requiring that physicians in the first year meet only five of the 25 meaningful use standards. Physicians should be required to report only three clinical quality measures -- and fewer if not enough apply to the practice's patients. Objectives and standards that don't apply to actual EMR adoption should be eliminated.
And CMS should redesign the initial plan into two segments to allow the criteria to phase in over a longer time, giving physicians another measure of needed flexibility.
These and other necessary changes will help make the road to widespread EMR adoption smoother for physicians and the federal government. At the end of the day, it is in everybody's best interests for doctors to get down that road safely, without crashing along the way.