While many healthcare providers are lucky if they’ve moved beyond even Stage 1 of Meaningful Use, policymakers are well into considering the potential details of Stage 3.

And that, of course, means stakeholders are considering their responses. The latest of those responses comes from the American Medical Association (AMA), who recently sent a letter listing its concerns and recommendations to ONC director Farzad Mostashari.

In summarizing its opinion, the group said “While the AMA shares the Administration’s goal of widespread EHR adoption and use, we are extremely concerned with the recommended approach to move full speed ahead without a comprehensive evaluation of the program and resolving existing barriers, including Health IT infrastructure flaws.”

What strikes us as telling about the group’s comments is that while they’re ostensibly directed at MU Stage 3, it seems more likely that they’re really about the MU program in its entirety.

For example, the group’s objections include:

“1. 100 percent pass rate is not the right 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.

“2. One size does not fit all.  Under the current program, every physician regardless of their specialty must meet the same measures (i.e., core measures), and there are few exceptions.  The program requirements should be appropriately flexible and betterstructured to accommodate various practice patterns and specialties.”

But it’s the third objection, including an explanation later on in the letter, that is perhaps the most potentially game-changing.

“3. Evaluation process is lacking and essential to improving the program,” the letter sums it up early on, but then it later explains:

“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.  It makes no sense to add stages and requirements to a program when even savvy EHR users and specialists are having difficulty meeting the Stage 1 measures.”

Obviously, an objection like this, if taken seriously by policymakers, could have significant implications for how the program proceeds.  We’ve long objected to the penalties that are slated to kick in next year, and the AMA’s objections essentially point to the reason.  The health IT transition is going to be long and drawn-out, and many things will be learned along the way – think “interoperability” – that suggest a specific timeline for the effort is, at best, counterproductive.  Penalizing providers for not keeping up with what is an increasingly complex process, if the need to solve newly discovered problems is factored in, makes little sense.

But what do you think?  Is the AMA onto something with its call for a formal, ongoing evaluation of the Meaningful Use program?

The AMA’s full letter can be found here.