The letter states that many family physicians have implemented and used EHRs “in the full spirit of the meaningful use program” and many expect the financial incentive to offset implementation costs and any initial decreases in productivity following go-lives. However, AAFP says the documentation requests for family physicians are “unreasonable and burdensome.”
The audits require primary care physician practices to provide documentation that may be a couple years old, according to the letter, which adds that such a requirement is especially difficult for physicians who have made changes to their practice or who may have been acquired by a larger organization.
Additionally, AAFP writes the auditing requirements, which generally entails back and forth communication with auditors, detracts from time physicians can spend on patient care.
The AAFP also notes the “all-or-nothing” audit approach is not fair, as a physician could fail an audit due to missing documentation instead of not meeting the requirements for meaningful use. “Missing one document may lead to a failed audit and a repayment of the full subsidy payment. The AAFP does not believe this is fair, nor does it encourage practices that have not yet adopted an EHR to pursue one.”
The AAFP asks for increased transparency from HHS regarding audit statistics, such as reports on what documentation was missing from failed audits to let eligible professionals more clearly understand what is needed.
“If the government believes that a strong primary care foundation is the key to an improved and sustainable healthcare system, then we urge you to take these issues into account and provide immediate and increased relief to those who have acted responsibly and legally and had no intent to defraud or deceive by participating in the meaningful use program,” the letter states.
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