July 30, 2010

Tom Sullivan, M.D.

Thoughts on the Final Rule on Meaningful Use

On July 13th HHS and the Office of the National Coordinator (ONC) released the “Final Rule” on Meaningful Use for EHRs (864 pages). This document lays out the requirements to qualify for the ARRA reimbursements in Stage I under CMS administration with the program starting in January 2011. The Rule for certifying EHRs to include certain standards (228 pages) was also released at that time, though for most physicians the former is far more important.
Most of the initial reactions were very positive, though in the past week some more nuanced comments have emerged along with critiques of the HHS reality checking engine assumed in the time line for adoption by physicians, especially small practices.
The American Medical Association (AMA) was one of the few organizations that did not issue a statement immediately. Their more detailed comments were encompassed in a 34 page memo to the AMA Board of Trustees on July 20th and in a press release on the 21st under the name of Steven Stack, MD, a Trustee who is an Emergency Room Medical Director from Kentucky and the AMA spokesperson for Health IT.
Here is an excerpt from his statement that addresses some of the problematic issues while overall complementing ONC and CMS for their efforts:
“Despite CMS’ attempt to simplify the meaningful use requirements, challenges remain. Among the concerns are questions about product availability, the tight time line for adoption and the high overall number of measures physicians are required to meet. While the volume of measures was reduced overall, the final rule requires physicians to meet 20 measures in the first year which is still too high, especially for smaller practices that are new to the technology.”
Currently there is no EHR in the market that does all the things required for physicians to successfully meet meaningful use criteria. CMS expects EHR systems that support meaningful use to become available this fall, giving physicians just a few months to purchase, implement and assess the usability of EHR technology before the January 1, 2011 start date of the incentive program. This is no small feat, considering it can take a year or more to purchase and implement an EHR system.
Some journalists and commentators are quick to claim that the AMA position does not carry much weight since most physicians are not members. This fails to recognize that, at well over 200,000 members, the AMA is still almost twice as large as the next largest medical association, the American College of Physicians (ACP). It is the only large professional association that has continuously, over many years, advocated in both governmental and private sectors for all physicians, regardless of specialty or membership status and has been vigorous in its position for safe, effective patient care and for physcians’ tools that are affordable and easy to use.
However, the “elephant in the room” – the SGR fix – is not mentioned in most of the commentary on the final rule which has the potential to put the additional reimbursements of $44-65k to physicians over a 4-6 year period in the proper context.
The looming 23% Medicare payment reduction that is continuously put off by Congress (recently pushed back to November 30th, and increased to 30% on January 1st) is the larger focus of the AMA at present. After years of Congress delaying a permanent SGR fix of the physician reimbursement formula, the cost of a “final fix” now runs well over $100 billion in the funny money accounting that goes on at the federal level. This amount dwarfs the ARRA meaningful use stimulus money for physicians and illustrates, in part, why the AMA feels more needs to be done to help physicians, especially small practices that can’t afford expensive IT systems and the ongoing training and support they require.
We at Dr First are well aware of all these developments and have been involved deeply and over a long time in making clinical IT systems simple, powerful and affordable. We were the first IT vendor to be chosen to take part in the AMA cloud computing initiative after they searched nationwide for the best eRx system to help launch their web based “Software as a Service platform (SAAS). Gradually, their system will offer more modules to help meet the Final Rule requirements.
On the other hand, the current Rcopia platform, and its soon to come innovative modules, offers the best bang for the buck for small practices, along with the ability to upgrade to any of more than 100 EMR applications that are represented in our DrFirst Partners program.

About Tom Sullivan, M.D.

Thomas E. Sullivan, M.D is a board-certified specialist in cardiology and internal medicine with over 40 years of clinical practice. He currently works for DrFirst and sees patients part-time in Massachusetts. His expertise in the application of information technology to health care has helped to create an international standard (ASTM) for the exchange of medical record information called the Continuity of Care Record (CCR). With AMA, he was founding chair of their e-Medicine Advisory Committee, worked with the Physician Consortium for Performance Improvement, represented the AMA and helped create the Physician EHR Coalition and is past chair of the AMA Council on Medical Service.