Calls for the Centers for Medicare & Medicaid Services to refrain from finalizing Meaningful Use Stage 3 are increasing, with the American Medical Association and the Medical Group Management Association adding their voices to the din.
Both organizations cite concerns over the proposed rule as it currently stands, with AMA saying in a letter to CMS Acting Administrator Andy Slavitt and National Coordinator for Health IT Karen DeSalvo that the program "will create significant challenges for physicians, patients, and vendors."
MGMA adds in its own letter to Slavitt that Stage 3 could result in a failure to meet the goals outlined in the American Recovery and Reinvestment Act of 2009. It should be delayed, MGMA says, until it is known what the impact of Medicare Access and CHIP Reauthorization Act of 2015 will be.
Concerns AMA addresses in its letter include:
- Safety of patients: The association says there is no evolution of how the requirements will impact patients. In addition, there are "huge gaps" when it comes to protecting patient data, AMA adds.
- Impact of Stage 1 and 2: More time is necessary to see the response of the industry to the modified versions of the first two stages of the program, as well as its ability to meet them.
- Interoperability: CMS must allocate more time to making interoperability priority, as well as reducing barriers to the exchange of data. The AMA says it recommends a certification program "focused on issues integral to interoperability, such as standardized vocabularies, patient matching, privacy, security, and high value use cases."
- 90-day reporting period for newbies: The association says removing the initial 90-day reporting period for new entrants will create an enormous barrier for them and could deter participation in the program.
For MGMA, changes it would like to see made to Stage 3 include:
- There should be no established measure thresholds until there is data from eligible provider participation from Stage 2
- Requirements made in the April 2015 Stage 2 modification rule should be adopted for 2015-2019
- Patients and third parties should not have to take action in order for a Stage 3 objective to be achieved by an EP
- Much like the AMA, MGMA says the proposed 90-day reporting period should be implemented for all years of the program, especially for new entrants
In addition to AMA and MGMA, the American Hospital Association also wrote to the Department of Health and Human Services asking the agency to hold off on finalizing Stage 3 until testing and refinement of standards can be conducted.
CHIME also criticized the proposal, calling Stage 3 "unworkable" in its letter to CMS. The organization says it doubts providers could successfully participate in 2018.