HIMSS and AMDIS Collaborate on Clinician Burden RFI Response Letter

Clinical burden and EHRs

On Monday, August 12, HIMSS and the Association of Medical Directors of Information Systems (AMDIS) provided written comments to the Centers for Medicare & Medicaid Services (CMS) in response to the request for information (RFI) on Reducing Administrative Burden To Put Patients Over Paperwork.

Our comments built on our January 2019 letter in response to the Strategy on Reducing Burden Relating to the Use of Health IT and EHRs where CMS collaborated with the Office of the National Coordinator for Health IT. HIMSS and AMDIS continued to emphasize that much of the work that clinicians face today is unnecessarily burdensome, where burden is defined as clinician activity that does not serve patient interests, does not improve quality or safety, or regardless of intent, is a barrier to clinical workflow and limits the ability of clinicians to appropriately engage with patients.

The themes of our response focused on helping CMS create an environment where the burden on clinicians is minimized, while prioritizing the ultimate goals of delivering better outcomes, higher quality and more cost-effective care.

Advance the Shift to Value-Based Care Delivery and Expand the Use of Alternative Payment Models (APMs) to Help Reduce Burden
Value-based care delivery should be prioritized as it can promote more useful documentation processes if the program is structured to focus on clinical outcomes that can be measured from the record without a requirement that turns clinicians into clerks.

Health Information Technology Tools are Part of Any Solution to Resolve Clinician Burden
Health IT tools are critical in resolving any burden-related issues in our healthcare system. When properly designed and utilized, health IT can reduce the burden associated with documentation, administrative functions and regulatory compliance.

CMS Should Work with the Entire Stakeholder Community to Map All of the Regulatory Requirements Placed on Clinicians in the Course of Care Delivery and Determine Areas of Convergence and Contradiction
CMS should catalog and summarize every regulation that influences clinical practice and determine the objectives of each included provision. This root cause analysis would help determine the regulatory provisions that are most burdensome and how they should be modified to meet each intended goal.

Given that the regulatory mapping exercise could take some time, we also suggested that CMS take several interim steps to reduce burden while it is underway, including: granting more physicians the ability to focus their energy on treating patients, not on documenting specific data elements that regulators and payers want included in EHRs; creating more robust resources to help demystify documentation requirements and show how they relate to coverage and reimbursement decisions; and, producing a resource guide that hospital and provider compliance departments could use for improved clarity on the documentation requirements for different clinical services.

CMS Must Shift the Paradigm from Requiring Clinicians to Submit Documentation to Payers for Coverage and Reimbursement Decisions to a Scenario where Health IT Tools and Approved Devices Send the Structured Data Elements that Payers Need to Make these Decisions Directly from EHRs
CMS should create an environment that allows health IT tools and approved devices to send structured data elements that a payer needs to make reimbursement decisions directly from the EHR and not require any additional steps or specified documentation from clinicians. Such a path would explore the use of a structured dataset to abstract content for payers to obtain necessary information, and would focus on the automated push-out of the specific information that a payer needs directly from the EHR or other health IT tool.

CMS Should Move to Finalize its Interoperability and Patient Access Proposed Regulation and Empower Patients with Greater Control of Their Data
CMS should focus on facilitating broader efforts around greater data sharing capacity and interoperability, as the lack of both of these end-states contributes to significant sources of clinician burden.

Quality Reporting Must be Prioritized When Seeking to Reduce Clinician Burden
HIMSS and AMDIS voiced support for a more holistic approach in terms of the professionals who can and do contribute to the reporting process as part of the care team, emphasizing the importance of approaching the strategies and recommendations for reducing documentation burden from a team-based healthcare perspective.

Reducing Burden May Help to Address Health Care Cost Challenges
Given recent scholarly research in this area, we emphasized the importance of addressing clinician burden in any plans to tackle health care cost challenges.

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