MGMA: Impose moratorium on MU penalties

The Medical Group Management Association (MGMA) officially weighed in on the Meaningful Use (MU) program, urging the Department of Health and Human Services (HHS) to institute an indefinite moratorium on penalties for physicians who successfully met MU Stage 1 requirements.

Without a hold on penalties, “we believe physicians that have made significant investments in EHR technology and successfully completed Stage 1 requirements will be unfairly subject to negative Medicare payment adjustments,” Susan Turney, MD, MS, MGMA president and CEO, wrote in an Aug. 21 letter to HHS Secretary Kathleen Sebelius.

While reiterating MGMA’s support for EHR adoption, Turney noted MGMA’s support for a one-year extension to the start date of Stage 2. The time extension and moratorium on penalties are needed, she wrote, because the alignment between the more rigorous Stage 2 requirements and the ability of the vendor community to produce and deploy Stage 2 certified products has not occurred at the pace anticipated.

Specifically, only 75 products and 21 complete EHRs are certified for the Stage 2 (2014) criteria out of more than 2,2000 products and nearly 1,400 complete EHRs certified under the 2011 criteria for ambulatory eligible professionals (EPs), according to the letter. “Without the appropriate software upgrades and timely vendor support, EPs will be unable to meet the Stage 2 requirements and thus will be unfairly penalized starting in 2015,” Turney wrote, noting that small or rural clinics are especially in danger of falling behind.

“We are also concerned that the current 'all or nothing' approach to achieving MU may prove to be problematic for EPs attempting to meet the more stringent Stage 2 requirements,” according to the letter.

MGMA added the following recommendations:

  • Extend the reporting period for Stage 2 incentives to a minimum of one year, while continuing the existing policy of requiring EPs to report for a 90-day period.
  • Extend the reporting period for Stage 1 incentives. Any EP who has attested for Stage 1 and whose EHR has not been recertified by January 2015 for the Stage 2 criteria should be permitted to continue to report Stage 1 criteria in calendar year 2014 without penalty
  • Conduct a comprehensive survey of vendors who were certified under the 2011 criteria on their MU Stage 2 plans
  • Build additional flexibility into the Stage 2 reporting requirements

The letter is accessible here.

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