EHRA critiques GOP's MU 'reboot' plan
One month after six Republican Senators published a white paper calling for a new approach to the federal meaningful use incentive program, the HIMSS Electronic Health Record Association has drafted a point-by-point response.
In their April report, "Reboot: Re-examining the Strategies Needed to Successfully Adopt Health IT," GOP Senators John Thune of South Dakota, Lamar Alexander of Tennessee, Richard Burr of North Carolina, Tom Coburn of Oklahoma, Mike Enzi of Wyoming and Pat Roberts of Kansas – all of whom voted against the American Recovery and Reinvestment Act when it first came before the Senate in 2009 – expressed concerns about the $35 billion allocated for health IT adoption as part of the stimulus bill.
They took issue with what they said is paltry progress on system interoperability so far, raised alarms about unnecessary billing enabled by EHRs, sought better oversight of the MU program, called for more stringent patient privacy protections and wondered about the chances for long-term health IT sustainability.
Stage 2 meaningful use, the senators wrote, “continues to focus less on the ability of disparate software systems to talk to one another and more on providing payments to facilities to purchase new technologies."
They called for a new approach to rule-making from the Office of the National Coordinator for Health IT and the Centers for Medicare & Medicaid Services, lamenting that a failure "systematically and clearly address meaningful groundwork for interoperability at the start of the program could lead to costly obstacles that are potentially fatal to the success of the program."
In a May 16 letter addressed to Thune et al., executives from EHRA, a trade group representing more than 40 EHR vendors, including Siemens, Allscripts, Greenway, Practice Fusion, NextGen, Cerner, McKesson and GE Healthcare IT, wrote that they "agree that in order for providers to best leverage health IT towards the aims of meaningful use and interoperability, Congress and the administration as well as providers and health IT developers will have to work together closely."
Still, EHRA had some "additional perspectives" on the senators' five areas of concern with regard to meaningful use.
When it comes to interoperability, EHRA made the case that "Stages 1 and 2 of the EHR Incentive Program and ongoing industry efforts have made significant advances toward broad interoperability."
The letter points to "growing numbers of health information exchanges (HIEs) and the availability of newer models of exchange (e.g., the Direct protocol and Integrating the Healthcare Enterprise (IHE) document management profiles)."
That said, "There is, of course, a substantial increase in complexity to attain interoperability when moving from connections within a single healthcare organization to attaining the same level of interoperability across provider organizations."
The association reminded the Senators that realizing true interoperability "involves many more stakeholders to resolve variations across thousands of different systems and implementations." That's something that "cannot happen overnight, but it is progressing rapidly and will be accelerated by requirements and capabilities in Stage 2 of meaningful use, as well as a result of a growing emphasis on delivery and payment system reforms, which are beginning to drive a real need for interoperability among stakeholders."
Responding to concerns about up-billing and increased costs, EHRA argued that, "We do not believe that data shows that EHRs or health IT have led to inappropriate or inaccurate coding or ordering of unnecessary care." In fact, "there is evidence that suggests that the use of EHRs can, in fact, decrease costs through the use of clinical decision support and other capabilities."
Yes, while EHRs "may allow documentation of services that were not easily documented in a paper world," the letter reads, "this capability allows for more accurate documentation and payment for the care that is delivered. … It is important not to undermine the ability of EHRs to make documentation more structured and efficient, nor their potential to lay the framework for a reformed delivery system."
As for a supposed lack of oversight, the association pointed out that "CMS has been conducting extensive post-payment audits and has recently initiated pre-payment audits, and the EHR Association is not aware of any evidence of widespread or significant instances of payments that were not warranted."
Moreover, "Stage 2 certification applies stricter tests of EHR capabilities for meaningful use and quality measure reporting," according to the letter. "Self-attestation is a feature of healthcare billing in general, and in our experience providers take their obligation for accuracy very seriously. Although clear safeguards must be in place, we do not want to undermine the incentive nature of the program or create unjustified burdens on providers."
When it comes to patient privacy, association members wrote that they of course take seriously "security and confidentiality of protected health information," and that they "believe that the combination of HIPAA requirements, which are incorporated by reference into meaningful use, as well as the technical security requirements built into product certification, provide an appropriate approach to privacy and security in the EHR incentive program."
Finally, to the question of sustainability, there's no question that "the end of the federal incentives to adopt EHRs will shift a burden back onto providers," wrote EHRA executives
That said, "We are confident in the larger value of EHRs as well as the ability of the market to generate innovative and cost effective solutions," they added.
As such, EHRA argued, that "with respect to Stage 3 meaningful use, we believe that this and later stages should focus on building on the solid foundation established in Stage 2 and not require significant, new meaningful use capabilities and associated certification changes that will require major EHR upgrades."
In addition, "We do not favor any halt in meaningful use payments given current and anticipated provider investments, as we continue our significant work to support our customers’ Stage 2 needs as they continue to adopt new and innovative approaches to care delivery with the assistance of EHR technology.
"In sum, the meaningful use incentive program should be maintained, with a more focused emphasis on the initial goals of outcomes improvements as well as responsiveness to the evolving market," wrote EHR Association Chair Mickey McGlynn, from Siemens, and Vice Chair Leigh Burchell, from Allscripts, on behalf of the HIMSS EHR Association Executive Committee.
"We are committed to continued collaboration with our customers, ONC and CMS, and other stakeholders to refine and improve the program and its administration to ensure that it serves the intended goal of achieving the promise of health IT as a key enabler in the transformation of the healthcare system," they wrote.
Read the HIMSS EHR Association's letter on the EHRA website.