ASCO Weighs in on CMS’ EHR Meaningful Use Proposal
In a letter Peter Paul Yu, MD, Chair of ASCO’s EHR Workgroup and Member of ASCO’s Board of Directors, sent today to the Acting Administrator of the Centers for Medicare and Medicaid Services (CMS), the specific concerns of oncology vis-à-vis EHR conversion are detailed in light of CMS’ proposed Meaningful Use requirements for incentive dollar qualification. CMS’ proposal is currently in the midst of the required public comment period, as reported in my post of 3/9/10, titled, “HHS Released NPRM for Two EHR Certification Stages”. Dr. Yu notes that while ASCO welcomes the benefits of EHR technology and has actively participated in making it effective in the oncology arena, few products available today make achieving Meaningful Use in the form proposed by CMS attainable for the oncology field.
Dr. Yu’s first concern is with regard to CMS’ “all-or-nothing” approach to meeting the proposed rule’s requirements. He suggests a “gradual progression towards full compliance of the various stages,” with 80% of the requirements to be met depending on the MU Stage. He is concerned that the 100% approach will detract small-and-medium-sized practices from even considering EHR conversion. That would result in greatly reduced CMS reimbursements to those practices by 2015 due to the penalty for not converting.
Dr. Yu argues that since there are currently few EHR systems on the market that are designed to meet all oncology-specific needs, it may be expensive, not to mention increase the risk of causing patient harm, for cancer providers to completely convert at this time. Many cancer centers and practices may wait until a product more conducive to oncology-based needs is released before even venturing into 100% EHR utilization. He goes on to say that ASCO does “not believe that oncologists choosing to wait for certified products that meet their needs should be penalized or receive less than the full incentive payment.” He also requests that the penalty stage of the legislation that is due to commence in 2015 be dropped.
The letter goes on to detail multiple points of the proposed law, followed by ASCO’s specific response and request for modification. It is a worthwhile read not just because it highlights the unique concerns of oncology and EHR systems, but because it clarifies many of the provisions of CMS’ proposal, itself. The letter can be found at http://www.asco.org/ASCOv2/Department%20Content/Cancer%20Policy%20and%20Clinical%20Affairs/Downloads/ASCO%20CMS%20MU%20Interim%20Rule%20Comments.pdf.