The federal government's proposed guidelines for what constitutes "meaningful use" of electronic health records technology are overly complex and too time-consuming for most practices to implement by 2011, according to an analysis by the American College of Physicians.

The guidelines stem from a provision in the American Recovery and Reinvestment Act of 2009, the so-called stimulus legislation, that pledged $19 billion toward the adoption of health information technology, such as electronic health records, by physicians' offices and hospitals to help modernize the nation's health-care system.

To determine who would be eligible for the incentive payments that are to accompany use of electronic records, the Health Information Technology Policy Committee, a federal advisory committee to the U.S. Department of Health and Human Services, developed "meaningful use" rules. The proposed rules were published in December, and interested parties had 90 days to submit comments.

Dr. Michael Barr, vice president of practice advocacy and improvement for ACP, said that the College is very supportive of the "meaningful use" concept but that some specifics in the proposed rule would place an unnecessary burden on physicians and their clinical teams, especially those at small- and mid-size practices.

"The challenge is getting the right information into the electronic health record needed to improve quality without creating additional and unnecessary work," Barr said. "The most important goal for 2011 'meaningful use' criteria should be to move eligible physicians and hospitals toward the routine capture of relevant clinical data in structured formats at the point of care."

In its comments, submitted March 10, the College indicated that the rules as currently written call for physicians to report on too many clinical measures and to make tabulations that would require labor-intensive, manual counting of activities done or, in some cases, not done.

For example, practices would have to determine the percentage of various activities done electronically, including transmitting prescriptions orders. Though the ability to track electronic prescriptions would presumably be built into an electronic records system, the ACP noted that it would be difficult and time-consuming for a practice to track prescriptions not ordered electronically in order to calculate the ratio.

"In terms of practicality, it becomes a challenge to come up with some of these denominators," Barr said. "We support the intent, but we really wanted to make sure the initial thrust should be data collection in a standardized way as a part of workflow to generate quality measures that can be used to improve patient care and reporting."

ACP stressed in its submitted comments that doctors and their staff should be able to collect the necessary data during their normal process of documenting their work and should not have to hire additional personnel, requiring expenditures over and above the costs of the software and hardware, just to meet the "meaningful use" requirements.

Key areas of concern cited by ACP in its comments were:

• The proposed rules require doctors to report on too many measures. "The amount of effort required to report so many measures is enormous," the College indicated. Some, such as recording height/weight in preventive care, might not be relevant in all situations.
• The pass-fail system of determining who is meeting "meaningful use" criteria means that a practice could miss out on the incentives for falling short in just one measure. Because of the complexity of the reporting rules, ACP said, "it seems highly unlikely that any physician or healthcare provider would be capable of reporting successfully on every metric." It also urged that practices serving as patient-centered medical homes be granted certain "equivalence" credits.

The College suggested that the rules be revised in several ways, including:

• Denominators that require manual counting of activities that cannot be captured electronically should be eliminated to avoid adding unnecessarily to the workload.
• Terms such as "order" and "test" should be defined more clearly to make sure that practices will understand what is expected.
• The rules should clearly state specifically who would be responsible for reporting each care activity to avoid duplicated efforts and waste.
• Requirements that have little to do with clinical outcomes -- such as checking insurance eligibility electronically -- should not be required to meet the "meaningful use" mandate.