In a detailed, 46-page letter dated February 25, 2011, the American Medical Association and 38 other medical societies raised serious concerns about the proposed set of requirements for Stage 2 of the Medicare/Medicaid Electronic Health Record (EHR) meaningful use incentive programs.

The letter, addressed to Joshua Seidman, PhD of the Office of the National Coordinator for Health Information Technology, warn that some of the proposed Stage 2 criteria depend on interconnectiblity infrastructure and two-way data exchange capabilities between physicians, hospitals and other providers that is currently not available.

“Physicians look forward to the day when they can securely exchange information with other providers to enhance the quality and efficiency of the care that they provide to their patients. However, asking physicians to do more within an environment that is still not largely interconnected, and in which commercially available products cannot perform the required functions reliably, will simply result in additional financial and administrative burdens, including the use of time-consuming dual processes—paper and electronic.”

A common thread in the comments is the inability of physicians to achieve measures that they cannot unilaterally accomplish without the efforts of others whom they cannot control -- patients, software developers, labs, hospitals, or governmental entities.

The medical societies make the following recommendations:

  1. CMS and ONC should survey physicians who elected to participate and those who elected not to participate during Stage 1 of the incentive program and identify barriers to and solutions for physician participation prior to moving to Stage 2;
  2. Measures for meeting meaningful use should factor in appropriate use. Physicians should be permitted to opt out of a measure that has little relevance to the physician’s routine practice;
  3. Prior to moving a measure from the Stage 1 menu set to the core set for Stage 2, or prior to adding new measures, a risk-benefit analysis should be performed, and any proposed new measure should initially be added to the “menu” set of criteria;
  4. High thresholds should be avoided for objectives that cannot be met due to the lack of available, well-tested tools or bidirectional health information exchanges; and
  5. Measures that require adherence from a party other than the physician should be removed (e.g., patient’s accessing patient portal, labs reporting test results).