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Nation’s clinical informatics professionals call on CMS to chart a course towards ending prescriptive measurement of health IT use

(BETHESDA, MD) — In comments submitted to the Centers for Medicare & Medicaid Services (CMS), the American Medical Informatics Association (AMIA) applauded federal officials for balancing burden reduction provisions with a need to continue making progress on health IT adoption and use. As part of the EHR Incentive Program’s continued evolution, the nation’s leading clinical informaticians called on CMS to abandon program reliance on prescriptive measures, in favor of hospital-developed improvement activities.

CMS announced in April several new proposals aimed at changing the EHR Incentive Program, also known as Meaningful Use, for hospitals. The newly renamed “Promoting Interoperability (PI) Program” 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.”

The proposed rule sought information on how CMS could enhance the program in future years to further nationwide interoperability, improve health information exchange, and promoting innovative uses of health IT. In response, AMIA called for a dramatic shift in how the PI Program of the future should be administered.

“AMIA recommends CMS abandon the construct of measure reporting in favor of an activity-based approach,” AMIA wrote in response. This approach, AMIA argued, “will enable organizations to demonstrate clinically meaningful use of health IT for their specific patient populations and priorities without forcing novel enactment strategies.” AMIA recommended replacing required measures with clinically-relevant “Inpatient Improvement Activities (IIAs).” While similar to the Improvement Activities under the Merit-based Incentive Payment System (MIPS) program, AMIA envisions that such hospital-specific improvement activities would:

  • Rely on the most recent Edition of Certified EHR Technology (CEHRT);
  • Align with a small number of broad strategic priorities established by HHS;
  • Be hospital-developed with a description of expected data inputs, processing, and action steps, with an assessment of impact;
  • Involve a high percentage of all clinicians who deliver care in the facility; and
  • Be posted publicly for purposes of transparency.

“Health IT facilitates better patient care, but it is not an end unto itself,” said Douglas B. Fridsma, MD, PhD, FACP, FACMI, AMIA President and CEO. “By enabling hospitals to demonstrate how they are leveraging clinical informatics, data analytics, and other such tools to address priority patient populations and improve patient care, CMS can provide the regulatory flexibility these tools need to be successful.”

Recognizing the difficulty in crafting such a program, AMIA recommended that CMS initiate a broad and inclusive conversation regarding the characteristics of IIAs, and further recommended the CMS Innovation Center (CMMI) initiate pilots to understand what systems and controls are needed to support this program. AMIA hopes that a revamped PI Program will be operational by 2021 for hospitals that are willing to transition away from prescriptive, numerator/denominator-driven measurement.

In addition to these long-term changes to the PI Program, AMIA urged CMS to avoid adding more requirements not currently supported by CEHRT. AMIA pointed to proposed measures not currently supported by 2015 CEHRT as requirements that should not yet be finalized. “A general principle CMS should follow is ensuring that ONC’s Certification Program supports all CMS requirements,” AMIA wrote.

AMIA strongly supported the proposed requirement for providers to use only 2015 Edition CEHRT starting in 2019, while underscoring the need to find ways to expand incentives for adoption to other settings of care.

“Without promoting CEHRT adoption beyond the original targets of external providers and acute care hospitals, the goal of promoting interoperability will be hindered and attempts to improve care quality will be stalled,” said Joseph Kannry, MD, Chair of AMIA’s Public Policy Committee and Lead Technical Informaticist, Mount Sinai Health System and Professor of Medicine, Icahn School of Medicine at Mount Sinai.  “CMS must leverage its rules and activities to support the ongoing adoption, implementation, and upgrade of CEHRT. Each stakeholder across the care continuum, including skilled nursing and long-term care facilities, pharmacies, and labs needs to use CEHRT-compatible technology. 21st century care of our patients demands it.”

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.