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RPA, Organized Medicine Sign-on Letter to House Leadership Opposing Implementation of Stage 3

Creation/Revision Date: November 02, 2015

November 2, 2015

The Honorable Paul Ryan 
U.S. House of Representatives 
232 U.S. Capitol 
Washington, DC 20515
                                      The Honorable Nancy Pelosi 
Minority Leader 
U.S. House of Representatives 
204 U.S. Capitol 
Washington, DC 20515
Dear Speaker Ryan and Representative Pelosi: 

On behalf of the undersigned state and national medical specialty organizations, we are writing to express our strong concerns with the decision by the Administration to move ahead with implementation of Stage 3 of the Meaningful Use program despite the widespread failure of Stage 2. While the overall goal established by Congress in the HITECH Act, namely to promote widespread adoption of electronic health records by physicians and hospitals, has largely been achieved, the Stage 3 requirements are inconsistent with the goal of promoting better coordinated and high quality patient care. Congressional action to refocus this program is urgently needed before physicians, frustrated by the near impossibility of compliance with meaningless and ill-informed bureaucratic requirements, abandon the program completely. 

Congress enacted the HITECH Act with the best of intentions and, in large part, the goals of the law have been achieved. In 2001, only 18% of physicians used electronic health records. Today, more than 80% have them. This was due in part to federal incentives, which helped to offset a portion of the cost of acquiring and operating the technology. However, as the regulatory scheme to measure “meaningful use” of this technology has evolved, the Centers for Medicare & Medicaid Services (CMS) has continued to layer requirement on top of requirement, usually without any real understanding of the way health care is delivered at the exam room level. What has emerged from this morass of regulation is a system that relegates physicians to the role of data entry clerks, filling the patient record with unnecessary documentation requirements unrelated to the provision of quality care. In addition, the program has failed to focus on interoperability and has instead created new barriers to easily exchanging data and information across care settings. 

The regulatory scheme developed by CMS envisioned three stages of increasingly onerous requirements for participants to demonstrate that they were “meaningful users” of the technology and to avoid reductions in Medicare reimbursements. Stage 2 of this program has largely been a failure, with only 12% of physicians successfully participating and little improvement in data exchange across care settings. CMS recently released modifications to Stage 2 to make modest improvements, though some new requirements will cause still more physicians to fail. 

Simultaneously CMS laid out more challenging requirements for Stage 3. Rather than build on the modest improvements made to Stage 2, CMS reverted back to the same fundamental flaws in the previous version of the program by focusing heavily on measure thresholds and excessive documentation requirements rather than improving interoperability. Relying so heavily on the failed construct of Stage 2 will only guarantee continued failure in Stage 3. 

Stakeholders have urged the Administration to take a different path to achieving the vision originally laid out by Congress in the HITECH Act. We believe that the success of the program hinges on a laser-like focus on promoting interoperability and allowing innovation to flourish as vendors respond to the demands of physicians and hospitals rather than the current system where vendors must meet the ill-informed check-the-box requirements of the current program. 

The Administration has not responded to this need and instead has chosen to perpetuate the current failed program through the release of Stage 3 Meaningful Use. It is unrealistic to expect that doing the same thing over and over again will result in a different outcome. We believe, therefore, that it is time for Congress to act to refocus the Meaningful Use program on the goal of achieving a truly interoperable system of electronic health records that will support, rather than hinder, the delivery of high quality care. 


American Medical Association 
Advocacy Council of the American College of Allergy, Asthma and Immunology 
Aerospace Medical Association 
AMDA – The Society for Post-Acute and Long-Term Care Medicine 
America Society for Radiation Oncology 
American Academy of Allergy, Asthma and Immunology 
American Academy of Dermatology Association 
American Academy of Emergency Medicine 
American Academy of Family Physicians 
American Academy of Home Care Medicine 
American Academy of Neurology 
American Academy of Ophthalmology 
American Academy of Otolaryngic Allergy 
American Academy of Otolaryngology—Head and Neck Surgery 
American Academy of Physical Medicine and Rehabilitation 
American Association of Clinical Endocrinologists 
American Association of Hip and Knee Surgeons 
American Association of Neurological Surgeons 
American association of Orthopaedic Surgeons 
American Clinical Neurophysiology Society 
American College of Cardiology 
American College of Gastroenterology 
American College of Mohs Surgery 
American College of Osteopathic Family Physicians 
American College of Osteopathic Internists 
American College of Osteopathic Surgeons 
American College of Phlebology 
American College of Physicians 
American College of Rheumatology 
American College of Surgeons 
American Gastroenterological Association 
American Geriatrics Society 
American Osteopathic Association 
American Psychiatric Association 
American Society for Clinical Pathology 
American Society for Dermatologic Surgery Association 
American Society for Gastrointestinal Endoscopy 
American Society for Surgery of the Hand 
American Society of Cataract and Refractive Surgery 
American Society of Clinical Oncology 
American Society of Dermatopathology 
American Society of Echocardiography 
American Society of Nuclear Cardiology 
American Society of Plastic Surgeons 
American Society of Retina Specialists 
American Thoracic Society 
American Urological Association 
College of American Pathologists 
Congress of Neurological Surgeons 
Heart Rhythm Society 
Infectious Diseases Society of America 
International Society for the Advancement of Spine Surgery 
Medical Group Management Association 
National Association of Spine Specialists 
North American Spine Society 
Obesity Medicine Association 
Renal Physicians Association 
Society for Cardiovascular Angiography and Interventions 
Society for Vascular Surgery 
Society of Hospital Medicine 
Spine Intervention Society 
Medical Association of the State of Alabama 
Alaska State Medical Association 
Arizona Medical Association 
Arkansas Medical Society 
California Medical Association 
Colorado Medical Society 
Connecticut State Medical Society 
Medical Society of Delaware 
Medical Society of the District of Columbia 
Florida Medical Association Inc 
Medical Association of Georgia 
Hawaii Medical Association 
Idaho Medical Association 
Illinois State Medical Society 
Indiana State Medical Association 
Iowa Medical Society 
Kansas Medical Society 
Kentucky Medical Association 
Louisiana State Medical Society 
Maine Medical Association 
MedChi, The Maryland State Medical Society 
Massachusetts Medical Society 
Michigan State Medical Society 
Minnesota Medical Association 
Mississippi State Medical Association 
Missouri State Medical Association 
Montana Medical Association 
Nebraska Medical Association 
Nevada State Medical Association 
New Hampshire Medical Society 
Medical Society of New Jersey 
New Mexico Medical Society 
Medical Society of the State of New York 
North Carolina Medical Society 
North Dakota Medical Association 
Ohio State Medical Association 
Oklahoma State Medical Association 
Oregon Medical Association 
Pennsylvania Medical Society 
Rhode Island Medical Society 
South Dakota State Medical Association 
Tennessee Medical Association 
Texas Medical Association 
Utah Medical Association 
Vermont Medical Society 
Medical Society of Virginia 
Washington State Medical Association 
West Virginia State Medical Association 
Wisconsin Medical Society 
Wyoming Medical Society

cc: U.S. House of Representatives

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