MMS on Meaningful Use Criteria: “Too Much, Too Soon”

119779298_9325985cc0_oThe MMS told the Centers for Medicare and Medicaid Services today that its proposed rules for a national electronic health record incentive program are too aggressive, and would deter  many physicians from participating in the program.

The MMS said the program “asks for too much, too soon” from many physicians, especially those in small practices. Read the MMS letter here. (.pdf, 6 pages)

The comments were a response to the federal government’s proposed  definition of “meaningful use,” the criteria that would determine whether physicians can recoup more than $40,000 of Medicare or Medicaid subsidies per person for installing an EHR. Today was the deadline to submit comments on the widely anticipated rulemaking.

Among the proposal’s shortcomings, according to the MMS:

  • Not enough representation from small practices on its advisory committee
  • Pediatricians are disadvantaged because few would meet the minimum 20% Medicaid patient panel to qualify
  • Specialists are disadvantaged because the criteria are focused on primary care physicians
  • The high administrative burden on small practices, who must redesign their workflow to implement an EHR
  • Hospital based physicians who also practice in outpatient clinics are unfairly excluded from the program

The MMS recommendations include:

  • Lengthen the schedule for adoption and compliance
  • Reduce the number of required criteria
  • Provide partial reimbursement for partial completion of the criteria
  • Create a separate track for those who do not yet have full health IT capabilities

The American Medical Association’s comments today were similar. In a document co-signed by 94 state and specialty medical societies (including the MMS), the AMA said it worries that physicians who install an EHR will find the requirements “overly complex and unattainable.”

The American Hospital Association called for a “rational timeline,” and criticized the lack of clarity in several sections of the proposed rules.

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