The American Medical Association (AMA) and College of Healthcare Information Management Executives (CHIME) have both submitted comments to the Office of the National Coordinator for Health Information Technology (ONC), laying out their concerns about – and suggestions for – meaningful use Stage 3.

“The AMA shares the administration’s goal of widespread EHR adoption and use, but we again stress our continuing concern that the meaningful use program is moving forward without a comprehensive evaluation of previous stages to resolve existing problems,” said AMA Board Chair Steven J. Stack, MD, in a statement.

[See also: Federal panel begins work on Stage 3 meaningful use]

“A full evaluation of past stages and more flexible program requirements will help physicians in different specialties and practice arrangements successfully adopt and use EHRs," he added.

In its letter to National Coordinator Farzad Mostashari, MD, the AMA offered five concerns and recommendations to improve the meaningful use incentive program.

First, the association questioned the lack of an external, independent review process, which it insisted was necessary to improve and inform the future of meaningful use. The Centers for Medicare & Medicaid Services (CMS) and ONC "have not evaluated the meaningful use program," wrote AMA's executive vice president and CEO James Madara, MD. "Given the concerns raised with the current program, an external, independent evaluation is necessary to improve and inform the future of the program."

Moreover, he wrote, "We believe that it is a serious mistake to keep adding stages and requirements to the meaningful use program without evaluating Stage 1 of the program. In addition, an evaluation should occur between each stage of the meaningful use program and prior to finalizing the requirements for the next stage."

[See also: Stage 3 goes for more rigor]

AMA also argues that a 100 percent pass rate was the wrong approach. "The current and future meaningful use requirements are problematic, given that failing to meet just one measure by one percent would make a physician ineligible for incentives and subject to financial penalties. The measures for use of EHRs should be made reasonable and achievable and still have a meaningful impact."

Relatedly, the association is expressing qualms about ONC's "one-size-fits-all" approach, calling for more flexible program requirements that take different practice patterns and specialties into consideration.

"Under the current program, every physician regardless of their specialty must meet the same measures (i.e., core measures), and there are few exceptions," according to the letter. "The program requirements should be appropriately flexible and better structured to accommodate various practice patterns and specialties. Also, additional resources and time to develop and test e-specified electronic measures focused on outcomes must be allotted to ensure successful implementation of the meaningful use program."

Usability was another chief concern. AMA called for the EHR certification process to address physician's concerns about design and ease of use.