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No Usability in Meaningful Use

September 17, 2014

Meaningful Use Stage 2 is coming to a theater near you.

A brief history: in 2008-2009 two acts created the incentive program for implementation of EHR that resulted in the Meaningful Use requirements:  HITECH (Health Information Technology for Economic and Clinical Health), and ARRA (American Recovery and Reinvestment Act).  The idea was that doctors who billed Medicare and Medicaid could get financial incentives to help them install EHRs in their practices, but only if the EHR and the doctor both ensured CMS that the EHR had “meaningful use”, i.e, that it did what CMS wanted it to do. It was supposed to be a phased-in process, and stage 2 requirements are more stringent than stage 1.

AMA board chair Steven Stack says that the AMA “has provided ongoing input since the inception of the EHR incentive program and has urged greater flexibility to make the program more reasonable and achievable for physicians.” This is sort of true.  On March 15, 2010 AMA executive vice president and CEO Michael Maves wrote a letter to then-head of Health and Human Services Kathleen Sibelius.  In it he said the following:

“On behalf of the physician and medical student members of the American Medical Association (AMA), I appreciate the opportunity to provide comments on the Department ofHealth and Human Services’ (HHS) interim final rule (IFR) on an initial set of standards, implementation specifications, and certification criteria for electronic health records (EHRs).  The AMA recognizes that an initial set of EHR standards, implementation specifications, and certification criteria are required to ensure that certified EHR technology is capable of supporting the achievement of meaningful use by physicians and other eligible professionals(EPs), as specified under the Medicare and Medicaid EHR incentive programs, beginning in 2011.”
Translation: Yeah, yeah, yeah, we understand you need to make sure you’re getting what you’re paying for.  We don’t like it, but we get it.
Then Maves goes on to the next sentence:
“Not only must EHR technology be “certified” to meet the meaningful use incentive requirements, but EHRs must also adequately meet a practice’s specific workflow and clinical needs.”
A still, small voice, as the Bible says.  Translation: “But…what about us?”  This particular sentence seems to have gotten lost in the political soup.

Last year, the American Hospital Association and the American Medical Association sent a joint letter to HHS Secretary Kathleen Sebelius asking for greater flexibility in the requirements of the meaningful use program:

“We appreciate the Department of Health and Human Services’ (HHS) decision to extend Meaningful Use Stage 1 through 2014.  Physicans and hospitals have made significant investments in health information technology (IT), which is evidenced by the increasing numbers of providers who are using EHRs and attesting to Meaningful Use.  We also share the administration’s commitment that no providers – or the patients they serve – are left behind as we proceed to Stage 2.  However, our members, and the vendors they work with, report growing concerns that the rapidly approaching start date for Stage 2 is on a trajectory that will not provide enough time or adequate flexibility for a safe and orderly transition unless certain changes are made.”

Translation: The beatings will continue until morale improves.

This year, the AMA has created a new framework for usability.  At least, they’re calling it new.  The rest of us have known this stuff for years.  Things like this:

1. Poor EHR design gets in the way of face-to-face interaction with patients because physicians are forced to spend more time documenting required information of questionable value. Features such as pop-up reminders, cumbersome menus and poor user interfaces can make EHRs far more time consuming than paper charts.  Amen.

2. Current technology often requires physicians to enter data or perform tasks that other team members should be empowered to complete.  No kidding.

3. Transitioning patient care can be a challenge without full EHR interoperability and robust tracking. Yup.

4. Few EHR systems are built to accommodate physicians’ practice patterns and work flows, which vary depending on size, specialty and setting.  Preach it!

5. Although physicians spend significant time navigating their EHR systems, many physicians say that the quality of the clinical narrative in paper charts is more succinct and reflective of the pertinent clinical information. A lack of context and overly structured data capture requirements, meanwhile, can make interpretation difficult.  Yes.

6. Data “lock in” is a common problem. EHR systems should facilitate connected health care across care settings and enable both exporting data and properly incorporating data from other systems. The end result should be a coherent longitudinal patient record that is built from various sources and can be accessed in real time.  Bring it to me Lord!

7. The meaningful use program requires physicians to use certified EHR technology, but many of these products have performed poorly in real-world practice settings.  Ya think?

“Physicians believe it is a national imperative to reframe policy around the desired future capabilities of this technology and emphasize clinical care improvements as the primary focus,” says Dr. Stack.  What would have been nice is if the AMA had pushed harder back in 2008 for regulations regarding usability and opposed regulation regarding meaningful use a little more.

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From → Healthcare

2 Comments
  1. nvt1 permalink

    Err – the AHA/AMA letter is from 2013…confused

    • Oh, Nick, thank you. Yes, you’re right, the AHA/AMA letter came out last year. But the “new” EHR usability guidelines are more recent. I’ll change that. But you know way more about this stuff than I do. How much input did the AMA have in the implementation of HITECH and ARRA at the physician level? Were any Meaningful Use criteria every challenged?

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