How industry groups line up on HHS plan to cut doc, reg burdens

Healthcare industry trade organizations believe that efforts to reduce evaluation and management coding will ease EHR-related documentation burdens.

This past November, the HHS Office of the National Coordinator for Health Information Technology issued a draft strategy to the healthcare industry to reduce administrative and regulatory documentation burdens associated with the use of electronic health records.

Now, the time period for industry comment on the draft report, available here, has closed, and a number of industry associations have submitted comment on the ONC strategy. They include the American Health Information Management Association, the American Medical Association, the American Medical Informatics Association, and the Medical Group Management Association, among others.

* AHIMA agrees with HHS’ recommendations to reduce regulatory and administrative burdens that hamper quality, and its members commit to ensuring electronic health record information is complete, confidential and an accurate depiction of all patients’ health stories. The association has created resources that include the CDI toolkit and the Copy Functionality Toolkit to help healthcare professionals ensure the accuracy, timeliness and consistency of clinical documentation.

However, while AHIMA agrees with the need to optimize EHR data, it is concerned with an HHS recommendation that data in scanned reports should be extracted and indexed for better retrieval, because of the cost of implementation and accessibility of the technology for small or rural provider organizations.

* The American Hospital Association told HHS that improving the ability for clinicians to use their EHRs to communicate with each other is essential high-value care and the government should consider ways to ease provider-to-provider communication.

AHA further agrees with other associations that reducing overall evaluation and management documentation also could reduce EHR-related burden. “However, we urge ONC and its partner agencies to continue to explore changes specific to EHR documentation that go beyond high-level changes to E/M documentation, as well as documentation requirements applicable to provision of care other than E/M visits, including care delivered via telehealth,” the AHA told Don Rucker, MD, National Coordinator for Health Information Technology.



* For the American Medical Informatics Association, representing the nation’s clinical informatics professionals, a priority is the need for the government to orient its documentation burden reduction strategy toward a long-term goal of decoupling clinical documentation from billing, regulatory and administrative compliance requirements.

This will help ensure that clinical decision support and quality/performance reporting are better positioned to improve care for patients and reduce burden for clinicians. That said, AMIA warned HHS that “the core challenge and dominant threat to the HHS strategy is that most electronic health records are designed to support transaction-based, fee-for-service billing requirements and business processes for regulatory/administrative compliance, rather than reflect clinical observation and treatment.

The group highlighted burdens that include Medicare Conditions of Participation, the Medicare Claims Processing Manual and the Office of Inspector General Work Plan, each of which compel EHR workflow design for their own purposes that increase provider burden. “Our regulatory and policy approaches need a paradigm shift so that our informatics tools can realize their potential to heal healthcare,” says Douglas Fridsma, MD, President and CEO of AMIA.

* Before the industry can reduce clinical and administrative burdens that plague providers, significant modifications to government policy in the areas of quality reporting programs, IT certification protocols, IT standards and other policy need to occur, the Medical Group Management Association, whose members deliver almost half of the nation’s care, told National Coordinator Donald Rucker. MGMA gave 9 ideas.

Reduce clinical documentation burden: The government should not move forward with its current plan to collapse Evaluation and Management payment levels.

Address prior authorization: This is perhaps the most onerous administrative burden for physician practices.

Publish electronic attachment standards: To end the practice of manually transmitting clinical information from practices to health plans, the government should establish the X12 275 electronic attachment standard and the supporting operating rules.

Reduce general MIPS burdens: Reduce the all-year reporting requirement for the quality component of the program, receiving credit in multiple catagories for meeting specific measures and offering a wide array of qualifying Advanced Alternative Payment models.

Modify MIPS promoting interoperability (PI): The PI component of MIPS should be simplified. Deploying 2015 Edition Certified EHR technology should qualify for the full 25 points. At minimum, the existing all-or-nothing approach should be replaced with a system that allows clinicians to score partial points from a wider variety of measure options.

Extend Stark and Anti-Kickback safe harbors:

The EHR donation exemption should be extended past 2021 and the types of technology and services permitted to be donated by group practices, hospitals and health systems should be expanded to include hardware.

Enhance Prescription Drug Monitoring Programs: One of the priorities of the SUPPORT Act covering substance abuse should be that interoperability between EHRs and PDMPs is required and that clinicians have easy access within their workflow to all state PDMP data.

Explore HL7 FHIR: MGMA supports exploring use of new standards such as HL7 and FHIR for clinical use and administrative transactions. However, physician practices have made great investment in the X12 electronic transactions and should not be mandated to adopt new and unproven standards. Clinicians and their organizations must be involved in the FHIR standards development process.

Consult with the physician practice community: With the vast majority of care delivered in medical practices, success or failure of health IT initiatives will depend on the ability of clinicians to efficiently and effectively incorporate technology and standards into their workflow. MGMA encourages federal agencies to continue outreach to clinicians to ensure requirements and concerns of practices are addressed.