MGMA Calls For Careful Design and Testing of Meaningful Use

As the deadline for the government to finalize its meaningful use and EHR certification criteria nears, the Medical Group Management Association (MGMA) has called on the Department of Health and Human Services (HHS) to take a fresh look at the work that has been done thus far to ensure that physicians will be fairly treated and that the program will have a good chance of success.

As those who have been following this story know, the HITECH Act included in last spring’s federal stimulus legislation offers financial incentives to physicians and hospitals for “meaningful use” of qualified EHRs. Among the requirements for meaningful use are electronic prescribing, the ability to exchange data with other providers and patients, and the reporting of quality data to the Centers for Medicare and Medicaid Services (CMS).

In a 5-page letter to David Blumenthal, MD, National Coordinator for Health Information Technology, MGMA CEO William F. Jessee, MD, warns that, if meaningful use is defined inappropriately and the program is poorly administered, the result will be “the needless squandering of resources and significant disruption to the nation’s healthcare system.”

Here are the highlights of the MGMA’s recommendations to avoid this situation:

• The meaningful use criteria should be easily adoptable in a wide range of practice settings, including small practices and rural practices.
• Between the date of the final rule and the 2011 start date of the incentive program, the government should conduct a pilot to ensure that “the process of demonstrating meaningful use is achievable and practical.”
• Instead of using a “pass/fail” structure, the government should inform physicians of whether they meet the criteria and give them an opportunity to modify their systems and submit corrected data.
• There should be a simplified process for physician attestation of their use of EHRs, to be verified through random audits.
• If vendors cannot provide “appropriate and cost-efficient products” that enable physicians to show meaningful use, the government should use its statutory authority to provide a low-cost EHR that meets those criteria.
• Doctors should be able to use a range of methods of reporting quality data, including claims-based information, and they should be able to test their reporting systems before the incentive start date.
• The government should create a website and toll-free telephone numbers so that physicians can report problems with vendors.

Most of these recommendations are appropriate. Even if they do not meet all the goals that the high-minded people on HHS’ Health IT Policy Committee are aiming for, the MGMA’s proposals embody a recognition that the real-world rollout of EHRs to hundreds of thousands of physicians is going to be a very complex, difficult, and long-term project. Just as great care must be taken to ensure the success of an EHR implementation in a single practice, even more thought, preparation and flexibility must be involved in a national program of this magnitude. While the HHS advisory committees have done a yeoman job of laying the groundwork, let’s do some reality checking before physicians turn their practices inside out in an effort to land government EHR subsidies.