- Healthcare organizations weighed in on the Office of the National Coordinator for Health IT's draft strategy on reducing regulatory burden from EHRs and other systems with calls for fewer reporting requirements, better alignment of documentation and workflow requirements and improved interoperability.
- In written comments to ONC, the American Hospital Association urged the office and CMS "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 that is delivered by telehealth."
- HIMSS and the Association of Medical Directors of Information Systems (AMDIS) said continued efforts toward standards-based interoperability would reduce the burden of sharing and using data, as well as reporting criteria around such exchanges.
Released in late November, the draft strategy focuses on three broad goals to relieve clinician burden: reducing time and effort associated with regulatory reporting requirement, cutting time and effort tied to inputting patient information in EHRs and increasing functionality and user-friendliness of EHRs.
Among its recommendations are to waive documentation requirements, as necessary, to test or administer alternative payment models and coordinate efforts to advance new approaches to supporting prior authorization. The strategy also suggests incentivizing innovative uses of health IT and interoperability that reduce reporting burdens and boost value for clinicians along with harmonizing reporting requirements across federally funded programs that require the same or similar EHR data from providers.
By and large, organizations praised ONC and CMS efforts to ease IT-related burdens. In a recent Medscape survey, nearly 44% of U.S. doctors reported feeling burned out. Among specialists who worked more than 50 hours, nearly half reported burn out. The chief culprit was "bureaucratic demands" such as charting and paperwork.
The American Health Information Management Association said clinical documentation improvement could help by "enhancing the accuracy, completeness, and trustworthiness" of data contained in health records. The group has developed CDI toolkits to assist with this goal.
The Pew Charitable Trusts called on ONC to address usability and safety challenges by ensuring some usability-related criteria focus on safety. It notes, for example, the 21st Century Cures Act's call for a voluntary certification program for EHRs used with children. In implementing this provision, ONC should look to some of its own recommendations such as requiring input from pediatricians and other end users.
HIMSS and AMDIS recommended creation of a minimum data set that payers, including CMS, would use to identify services delivered during a patient visit and confirm payment decisions. They also suggested creating a sort of roadmap that compliance departments could use to communicate documentation requirements to clinicians.
"In the longer term, HIMSS and AMDIS encourage HHS to think more broadly about how to shift the paradigm from requiring clinicians to submit documentation to payers for coverage and reimbursement decisions to a scenario where health IT tools and approved devices send the structured data elements that payers need to make these decisions directly from an EHR," the groups wrote.
With the shift to value-based care, ONC and CMS should also consider new nontraditional stakeholders and data sources to reduce regulatory burden, HIMSS and AMDIS said. They pointed to the HHS Administration for Children and Families, which has provided feedback to the department on development of standards for data exchange related to social determinants of health.
A number of groups also cited the forthcoming API regulations as critical to reducing burden. In implementing this policy, ONC should ensure APIs permit clinicians to access individual data elements without having to receive the entire patient record, Pew said, adding use of the FHIR standard could enable this goal. Pew also said information coded in a standard format or terminology should be allowed to retain that structure even if it is not widely used, rather than converting it to a "less-usable configuration" like a PDF.
On prior authorization, AHA said HHS should work with clinicians, payers, medical product companies and health IT developers to standardize the process, as well as information required by utilization programs. "All stakeholders also should consider how to reduce the need for prior authorization, particularly as we improve documentation and move to new models of care that put more financial risk on providers," the group wrote.
Commenters also took issue with some of the recommendations on improving health IT usability and the user experience.
For example, AHIMA said that while requiring data in scanned reports to be extracted and indexed could improve retrieval, the cost of accessing and implementing such technologies could be burdensome for small and rural facilities.
AHA slammed ONC's recommendation that providers increase their budgets for health IT training. "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 group said.
Several groups said artificial intelligence should be considered as a burden-reduction tool. HIMSS and AMDIS urged HHS to fund a study of to explore how that might be done. Potential use cases include parsing reams of data in a clinical note to extract the nuggets of information most relevant to the patient's case or aiding in diagnosis, the groups said.