January 30, 2019

The amount of time that clinicians and healthcare organizations are required to spend fulfilling federal documentation requirements regarding patient care is often cited as a major cause of burnout and stress among healthcare professionals. In an effort to simplify these requirements and relieve the strain, the Office of the National Coordinator for Health Information Technology (ONC) in November issued a draft strategy to reduce regulatory and administrative burden related to health information technology (HIT) and electronic health record (EHR) use.

In comments to the ONC regarding the proposal, the American Hospital Association (AHA) this week provided feedback in the following areas, among others:

Evaluation and management documentation. The AHA stated that while it appreciates ONC’s recognition of the “double-edged sword” providers experience regarding the simultaneous patient care benefits and administrative burdens of HIT and EHRs, and agrees with ONC that reducing evaluation and management (E/M) documentation requirements is an important component of the strategy, the E/M documentation changes currently slated to go into effect in 2021 “will not have a meaningful impact on providers’ availability to spend time with patients.”

To address this problem, the organization urged ONC to ensure that any mechanism for gathering stakeholder input on the new E/M requirements before they become policy “include a majority of participants from the clinical community, hospitals and health systems.” It also asked ONC to evaluate all potential new requirements in light of their impact on administrative burden.

Prior authorization. While the AHA commended ONC for its plans to streamline prior authorization processes by adopting standardized templates and other improvements, it asked the agency to “build on existing work by first thoroughly reviewing the current standards and including these in ongoing discussions so that the agency does not compromise the work done to develop the HIPAA-mandated transactions.”

The AHA also said that while it supports the development of standardized data and processes in relation to prior authorization, it hopes ONC will ensure that its final strategy encompasses consideration for “issues around broadly applied prior authorization programs that impose significant administrative burdens on all health care providers.” Currently, providers must identify and comply with each entity’s unique requirements, and that lack of standardization is a major source of administrative burden.

Reporting requirements. AHA urged HHS to take steps to better align clinician reporting requirements across the Medicare and Medicaid Promoting Interoperability Program (PIP), noting that while Medicaid requirements in 2019 rely on relatively rigid, historical meaningful use criteria, Medicare has moved to a more flexible approach. That variation, and the time providers must devote to complying with the different requirements, adds significantly to providers’ administrative load.

The AHA also asked ONC to work with state prescription drug monitoring programs (PDMPs) to improve integration into EHRs and data sharing across state lines. An open, standard application programming interface could help greatly in this regard, AHA stated.

The organization also called for improvements in systems clinicians and organizations use to report quality data; a requirement for all electronic clinical quality measures (eCQMs) to first receive the endorsement of the National Quality Forum; and support for states in developing their ability to receive data and adhere to standards for certified EHRs for public health reporting purposes.

Health IT usability and the user experience. The AHA disagrees with ONC’s recommendation that healthcare providers consider increasing their training budgets as a strategy for addressing provider complaints regarding EHR usability. “While training is clearly essential, and must be funded, usable systems developed according to user-centered design principles should be intuitive and facilitate both rapid onboarding and ease acculturation to changes in the software,” the organization said, also citing interoperability’s important role in usability. The AHA supports the use of machine learning, natural language processing and artificial intelligence to enhance usability overall.