Concerns Expressed on Implemenation of Stage 2 Meaningful Use Criteria

“...there has been little to ensure that specialists have the same ability to meet the criteria and earn the incentives (and, avoid the penalties) in the EHR Incentive Program...”

The Heart Rhythm Society, as a member of the Alliance of Specialty Medicine, has provided feedback on the Health Information Technology Policy Committee’s proposed set of requirements for stages 2 and 3 of the Electronic Health Record (EHR) Incentive Program. The comment letter (PDF, 180K) was addressed to the Office of the National Coordinator for Health Information Technology (ONC) and focused primarily on the stage 2 compliance and demonstration of Meaningful Use of EHRs.

Stage 2 Meaningful Use criteria aim to help foster a robust structure for data exchange, so that computers and doctors can exchange data seamlessly. The stage 2 criteria released by the ONC provided thresholds of performance to determine if a practice, hospital or institution has incorporated EHRs to the extent approved by the Office of the National Coordinator. Meeting these goals would allow the provider to qualify for incentive payments from the “Stimulus bill” through Medicaid and Medicare.

The Society previously commented that stage 1 meaningful use criteria have been overly focused on primary care physicians. The stage 1 goals were difficult for specialists to meet; jeopardizing their changes to earn the incentives and avoid the penalties in the EHR Incentive Program. There is a concern that ONC now has increased the threshold levels of complying with stage 2 meaningful use criteria without correcting the disadvantages for specialty medicine in the stage 1 meaningful use criteria.

The letter urges ONC to reconsider recommendations that would increase the thresholds levels for compliance until sufficient data have been collected regarding whether providers are able to meet the stage 1 criteria. The letter recommends that a certain percentage of providers meet stage 1 compliance before moving to stage 2. The letter also requests that those providers who have attempted but not yet been able to meet stage 1 criteria are given more time to change their practices, in lieu of applying penalties for noncompliance.

The Health IT Policy Committee stated that it will consider all comments in forming the stage 2 meaningful use recommendations it presents this summer to the U.S. Department of Health & Human Services. The Society will continue to monitor developments as they progress as well as the effects of electronic health records on electrophysiologists.