After proclaiming its long-standing commitment to the implementation and use of health information technology, the American Academy of Family Physicians enumerated a litany of concerns it has with the Meaningful Use NPRM, still out for comment until March 15. “ … we believe that certain aspects in the details of these regulations are unworkable, excessive, or redundant, and will actually impede the very goals of the legislation,” read the letter from AAFP Board Chair Ted Epperly, M.D.
Among the areas AAFP would like to see CMS “significantly modify the proposed rule” are:
- Increased Participation Through Partial Incentives — AAFP wants the “all-or-nothing” approach replaced with a partial incentive program.
- Increase Achievement of Meaningful Use through Focused Reporting — AAFP is “very concerned about the administrative burdens that would be placed on eligible physicians to report the measures as propose.” The organization wants to move away from tracking non-electronic orders (i.e. denominators), toward recording absolute counts.
- Do Not Exclude Primary Care Physician in Hospital Organizations — Like a number of other organizations, AAFP wants hospital-based docs included in the program. “Family medicine includes several residencies and practices that bill under the hospital facility type, but they are responsible for the investment in health IT.”
- CPOE — “We believe that the administrative burden to report on the CPOE measure is excessive to the point of being unachievable for most eligible providers. Many eligible providers will have to perform double entry, as many laboratories, hospitals, and diagnostic imaging centers do not accept standard electronic orders and the practice would be required to keep a registry of all non-CPOE orders to calculate the denominator. Based on the current state of adoption of CPOE in the ambulatory environment and the issues stated above, we recommend that the CPOE measure be removed until electronic orders are routinely transmittable.”
- Incorporate Clinical Lab-test Results — “We are concerned about the administrative burden of entering all of the results manually for those practices that do not have access to a lab interface. There currently is no requirement for laboratories to provide EHR interfaces, which provide these discrete lab-test results. Requiring that the eligible providers purchase an EHR technology that has the ability to receive these results only works when the source of the lab results has the ability and will to send them with the same standards.” AAFP proposes a “hardship clause” for practices that have lab test data sources currently that can’t provide electronic interfaces.
In a number of places, the organization makes the point that requiring small practices to implement advanced technical interfaces for clinical information exchange will put them at the mercy of wolfish counterparties. “We believe there is a real risk for entities to gouge eligible providers to ‘assist’ them with such testing.”