The AAMC Jan. 28 submitted comments to the Office of the National Coordinator (ONC) on the draft strategy to reduce regulatory and administrative burden related to health information technology (HIT) and electronic health record (EHR) use. The draft, Strategy on Reducing Regulatory and Administrative Burden Relating to the Use of Health IT and EHRs, is a joint effort between the ONC and the Centers for Medicare and Medicaid Services (CMS) to reduce burden and meet the goals of the 21st Century Cures Act (P.L. 114-255).
In its comments, the AAMC praised ONC for its effort to address the undue burden that EHRs and other technologies place upon health care providers and systems. However, the AAMC urged ONC and CMS to refine their approach to evaluation and management (E&M) payment in the future, and to seek the input of stakeholders as part of this effort. The AAMC pointed out that while it supports many of the documentation changes to E&M services, there are continued concerns about the potential for negative unintended consequences related to a single payment rate for levels 2 through 4 outpatient office visits that was finalized in the 2019 physician fee schedule rule. The AAMC also commented on the need to standardize data and processes around ordering services and related prior authorization processes and urged ONC to take steps to improve the usability and user experience of HIT broadly.
With respect to EHR reporting programs, the AAMC commended CMS for taking steps to align the Promoting Interoperability (PI) category in Merit-based Incentive Payment System (MIPS) and the Promoting Interoperability Program for hospitals, which has helped to reduce provider burden. However, the AAMC expressed concern about other aspects of the Promoting Interoperability program and encouraged additional refinements to improve flexibility and reduce burden, including the elimination of the rigid, all-or-nothing scoring methodology of the PI category under MIPS.