AMCP comments on 'meaningful use' criteria
Concern:
The pace at which eligible providers (EPs) are required to adopt electronic health records in order to receive incentive payments may adversely impact patient safety and access to pharmacy services.
Recommendation:
- AMCP strongly encourages CMS to develop criteria that would allow additional time beyond the current October 2010 date for eligible providers to demonstrate meaningful use by adjusting the timeline and threshold requirements for e-prescribing in specific market segments where lack of capital for investment can be documented and where pharmacy and other health care provider access is limited. Further, a specified future date should be established only after e-prescribing standards for prior authorization, drug name nomenclature, codified prescription instructions and controlled substances are fully tested and integrated into certified electronic health record and e-prescribing systems.
Concern No. 2:
Meaningful use objectives for 2011 are not adequate to ensure that sound medication therapy management can be achieved.
Recommendations:
- AMCP recommends modifying the measure for maintaining an active medication list to require a complete and accurate medication list be maintained within the electronic health record. AMCP contends that the current measure for requiring 80% of all unique patients to have at least one entry (or an indication of “none)” will not cause the provider to use the electronic health record system to maintain a complete and accurate list and therefore not support medication reconciliation in ameaningful way.
- AMCP further recommends that the objective measure for medication reconciliation include a requirement that the medication reconciliation findings be appropriately documented and communicated using a certified electronic health record that supports bi-directional clinical information exchange among the patient’s health care providers, pharmacies and payers.
The Academy of Managed Care Pharmacy (AMCP) provides formal comments on the 'meaningful use' criteria, focusing on two areas of concern directly related to medication therapy management.
