The Chicago-based American Medical Association (AMA) officially submitted its comments this week on the proposed rule for Stage 2 of the Medicare/Medicaid meaningful use electronic health record (EHR) program. Overall, the association said it was supportive of widespread adoption and meaningful use of EHRs by physicians, but thought the Stage 2 proposal was too cumbersome and would make successful physician participation extremely difficult.

“Due to physicians’ limited ability to exchange data with other health care partners, many of the proposed Stage 2 measures will require extensive manual data entry, which is not an efficient way of practicing medicine or improving quality care outcomes for patients,” AMA Board Chair-elect Steven J. Stack, M.D., said in a statement.

The AMA made several recommendations to the Office of the National Coordinator for Health IT (ONC). Among those suggestions were to ‘delete the high thresholds for new measures and for measures that cannot be met due to the lack of available, affordable, well-tested tools or exchange capabilities.’ The group also asked for the elimination of back-dating the meaningful use penalty program and to establish a number of exemption categories for hardship cases.

Other changes recommended by the AMA were:

• Evaluate Stage 1 to inform the final Stage 2 requirements;
• Create more flexibility in meeting measures including exclusion and relevancy factors;  
• Incorporate more focus on measures within a physician’s control;
• Include any proposed new measures for Stage 2 in the menu set of options;  
• Allow a significant good faith effort to meet measures in Stage 2 to count for incentives and for avoiding penalties;    
• Synchronize and improve the overlapping health IT and quality program requirements; 
• Establish an appeals process under both the meaningful use and e-prescribing programs; and
• Reduce the burden and add flexibility in regard to clinical quality measure (CQM) reporting and requiring testing of electronic specifications prior to use of a CQM.  

“Overall, the proposed Stage 2 requirements need to provide more flexibility to foster widespread EHR adoption,” Dr. Stack said in a statement. “Physicians are at varying stages of implementing health IT into their practices and should get credit for making a good faith effort to meet the meaningful use requirements.”