"Usability standards being included in the certification criteria will be critical for ensuring that physicians invest their resources in EHR, CPOE, as well as other health IT products that work for them," writes Madara. Physicians are worried about the viability of the systems in which they've invested, and are "concerned about potential liabilities from EHR system design and software flaws as well as lack of interoperability among EHR systems that could result in incomplete or missing information, which may lead to errors in patient diagnosis and treatment (e.g., patient matching)."

Finally, the AMA called for progress on breaking down infrastructure barriers that are hindering information exchange. "Improving the health IT infrastructure to allow physicians to readily and securely exchange patient data with other health care providers should be made a top priority and take precedence over the development of future stages of the meaningful use program."

While meaningful use has helped to jumpstart EHR adoption, "We are still in the early stage of progress due to technological, financial, operational and regulatory challenges," wrote Madara. "These challenges must be overcome in order to increase physician participation rates and maximize the benefits of this technology for our nation’s health care delivery system."

 Read the full AMA letter here. 

Don't "cram everything into" MU Stage 3
On Jan. 14, CHIME submitted its own comments to ONC officials, calling on them to reconsider the speed and scale planned for achieving Stage 3 meaningful use objectives by 2016.

CHIME, too, urged HIT Policy Committee to recommend "thorough evaluations of what has been accomplished thus far" so as to ensure that objectives for Stage 3 are realistic and achievable.

“We see no value in setting unrealistic performance thresholds or expectations before current evaluations of what we have accomplished have been undertaken,” said CHIME President and CEO Richard A. Correll and Board Chair George T. Hickman in their letter. “[E]very desirable EHR-related objective cannot feasibly be met by 2016, nor do we see any value in attempting the rushed adoption of various EHR uses by that time. Instead, verifiable and continuous progress should be the goal.”

“One of our main messages to regulators is that we shouldn’t look to cram everything into Stage 3,” said Pam McNutt, senior vice president and CIO at Dallas-based Methodist Hospital System, and member of CHIME’s Policy Steering Committee, in a statement.

“The modernization of America’s healthcare system is a decade-long progression," she added. "We need to make sure that the HIT Policy Committee is looking at more than just the Stage 2 measures and objectives when making recommendations to HHS; that’s why we strongly urged thorough evaluations of to-date accomplishments and progress.”