sician members can do is ask practi- cal questions that cause CMS to define things more carefully and more reason- ably as the agency interprets the rules,” he said. “We need to ensure the mean- ingful use Stage 2 criteria are truly meaningful, not just boxes to check that satisfy a requirement. The measures should ensure physicians are using their EHRs in ways that truly benefit patients and medical practices.”
In its 14-page comment letter to CMS, TMA specified three broad suggestions to improve the proposed Stage 2 rules. TMA said CMS should:
1. Carefully align meaningful use goals with market ability. Hastily devel- oped systems jeopardize patient safe- ty, TMA wrote, adding that much of meaningful use value comes from the capability for health information ex- change (HIE). The association point- ed out that most funded HIEs in the state cannot yet effectively exchange patient information and suggested CMS analyze market capabilities to ensure the marketplace is ready for all proposed criteria.
2. Provide adequate exclusions so that physicians can fully participate in the program.
3. Give physicians forced to switch EHRs (for example, due to a vendor deci- sion to discontinue a product) a way to participate in the Medicare mean- ingful use program without losing a year of incentives during the transi- tion. “With over 1,200 certified EHRs this will be a likely issue as the crite- ria become more difficult for smaller EHR companies, forcing them to ei- ther close or be sold to a larger com- pany,” Dr. Schneider wrote.
The association recommended CMS allow physicians to meet only 90 days of meaningful use during the 2014 transi- tion, and the agency heeded TMA’s ad- vice. The rule allows physicians to meet the reduced reporting period because of EHR vendors’ need to upgrade their systems to meet new certification re- quirements adopted by the Office of the National Coordinator for Health Infor- mation Technology (ONC).
Log on to
www.texmed.org/MU 2Comments.aspx to read the letter.
TMA weighs in
The EHR certification rules complement the CMS meaningful use Stage 2 rules. The ONC fact sheet on the rules related to standards, implementation specifica- tions, and certification criteria for EHR technology is available online, www
.healthit.gov/sites/default/files/pdf/ ONC_FS_EHR_Stage_2_Final_082312 .pdf.
TMA submitted an 11-page com- ment letter to ONC on its proposed EHR technology standards and certification rules in May. In the letter, signed by Dr. Schneider, TMA cited the example of the hefty expenses one Texas physi- cian faced when forced to transition to another EHR system. An EHR vendor discontinued a product the physician purchased nine months earlier. “The new product that the vendor
recommended cost twice as much as the product initially purchased. Because of the price difference, the physician shopped around and decided to switch to another company. The cost for the
physician to migrate only nine months of patient data was $12, 000,” Dr. Schnei- der wrote. To remedy the problem and reduce the price associated with transferring data, TMA recommended CMS and ONC require vendors to tag key data elements that would typically be moved in an EHR transition with standardized XML, and to receive and process data with standardized XML. At this time, such a requirement isn’t part of the rules. Dr. Schneider and TMA also called on the agency to establish a single entity to which physicians could report EHR vendor problems that negatively affect patient safety without fear of vendor retaliation.
TMA explained that despite the ben-
efits of EHRs, patients can be harmed by EHR problems. For example, an EHR could have a programming malfunction that prevents it from saving a physician’s notes in a patient’s record. “By having a reporting and tracking mechanism that is designated as the sole place to report such issues, indus- try can quickly be made aware of and respond to such issues. This mechanism
Medicare and Medicaid incentives
Health professionals in the Medicare incentive program can earn up to $44,000 over five years for meeting meaningful use criteria from 2011 to 2016. Eligible Medicare physicians in a health professional shortage area can receive a 10-percent increase in incentives.
Eligible non-hospital-based physicians with at least 30-per-
cent Medicaid patient volume can receive up to $63,750 over six years in incentive payments from 2011 to 2021. Eligible non- hospital-based pediatricians with at least 20-percent Medicaid patient volume could receive up to $42,500 during the same period.
December 2012 TEXAS MEDICINE 35
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