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Nation’s clinical informatics professionals call on CMS to leverage ‘passive data collection’ to improve clinical documentation using health IT

(BETHESDA, MD) — In comments submitted to the Centers for Medicare & Medicaid Services (CMS), the American Medical Informatics Association (AMIA) applauded federal officials for aligning physician and hospital EHR requirements and advancing policies that further incentivize the adoption of health IT for patient care. AMIA also supported CMS efforts to reduce documentation burden through new options to use time or Medical Decision Making (MDM) as a basis to determine Evaluation & Management (E&M) visit level.

CMS announced in June several new proposals aimed at reducing documentation burden through E&M guideline reforms, increasing the use of “virtual care” codes, and streamlining MIPS participation, which includes the newly renamed “Promoting Interoperability (PI) Program.”

As part of E&M guideline reforms, CMS proposed to allow physicians the option to use time or MDM as a basis to determine E&M visit level. In its comments to CMS, AMIA noted its, “history of leadership in commenting on EHR documentation challenges in the E/M era,” supporting both the use of MDM and time as alternative means to determine appropriate level of E/M visit. “However,” the group noted, “determining levels of MDM is a convoluted and complex task under current guidelines. This complexity must be addressed with an eye towards how IT and informatics can be leveraged so the simplicity of these solutions can be realized.”

AMIA said there was “great promise” in the use of passive “behind the scenes” data collection, facilitated through EHRs and other health IT to both reduce clinical documentation burden and improve billing precision. AMIA recommended CMS support their proposed E&M reforms with focused and well-resourced efforts to leverage these current functions and develop emerging functions, such as natural language processing, medical device data, voice recognition software, and the use of sensors to capture clinical activity. “Acknowledging that these and other informatics tools are still early in development,” AMIA said, “CMS should support pilots and otherwise incentivize efforts meant to use these kinds of technologies and evaluate their use for documentation purposes.”

“Our current documentation paradigm is incompatible with the digital age,” said Joseph Kannry, MD, Chair of AMIA’s Public Policy Committee and Lead Technical Informaticist at Mount Sinai Health System and Professor of Medicine Icahn School of Medicine at Mount Sinai. “While imperfect, CMS must proceed with E&M documentation reforms to address growing dissatisfaction and declining wellness among clinicians. Our billing-focused health IT ecosystem must be reoriented to patient care.”

Beginning in January 2019, CMS proposed to reimburse physicians for engaging in “virtual care,” for “brief communications,” “remote evaluation,” and “interprofessional consultation.” AMIA applauded CMS for recognizing the increased state of digitization in healthcare delivery and thus proposing to reimburse providers accordingly.

“We view these policies as addressing long-standing Medicare reimbursement barriers to widespread adoption of virtual care tools meant to reach more patients in more places, especially those in underserved and rural areas,” AMIA said. However, AMIA noted specific concerns related to the context of these new virtual care codes and encouraged CMS to consider issues related to clinical effectiveness, patient authentication, and proliferation of data silos derived from telehealth applications.

CMS also proposed to harmonize physician and hospital EHR requirements related to the PI Program. Mirroring proposals finalized for hospitals in 2019, CMS would require the use of 2015 Edition CEHRT 2019 and continue a 90-day EHR reporting period through 2020. The PI Program would also include a new points system scoring methodology and fewer required measures for hospitals to report. AMIA largely supported these proposals, while recognizing that important functionalities related to retired patient engagement measures, such as secure messaging, education, and use of patient-generated health data, must remain part of CEHRT.

“Meaningful Use has served as a valuable vehicle to help digitize care delivery in the United States and thereby enable informatics-driven improvements in patient safety and clinical care,” said Peter J. Embi, MD, MS, FACP, FACMI, AMIA Board Chair, and President and CEO, Regenstrief Institute. “But now is the time to think differently about how this program should evolve to meet the rapidly-changing, and often challenging, environment of care delivery. These new proposals position the program to build on progress made to-date, and our recommendations provide impetus for even more innovative changes focused on the ultimate goals of improving health and health care.”

Click here for AMIA’s full response to CMS proposals.


AMIA, the leading professional association for informatics professionals, is the center of action for 5,400 informatics professionals from more than 65 countries. As the voice of the nation’s top biomedical and health informatics professionals, AMIA and its members play a leading role in assessing the effect of health innovations on health policy, and advancing the field of informatics. AMIA actively supports five domains in informatics: translational bioinformatics, clinical research informatics, clinical informatics, consumer health informatics, and public health informatics.