THE VALUED VOICE

WHA Recommends to HHS Reforms to Reduce EHR Documentation Burdens

Disappointed in lack of guidance for CAHs

WHA recommended several federal policy changes to reduce regulatory and administrative burden relating to electronic health record (EHR) use in a comment letter submitted to the Department of Health and Human Services (HHS) January 28. The comment letter was in response to a series of recommendations made in an Office of the National Coordinator for Health Information Technology report focusing on addressing specific sources of EHR-related clinical burden released in December.

WHA thanked HHS for the report’s “thoughtful approach to identifying EHR-related sources of regulatory burden, and encourage[d] HHS to continue to seek input from the field to identify additional regulatory reforms to reduce EHR-related regulatory burden on organizations, administrators, physicians, and other clinicians when such regulations do not meaningfully improve health care quality, safety and efficiency.”
Building upon input received from the WHA Physician Leaders Council and other member input in 2018 to reduce physician regulatory burden, WHA made several recommendations to HHS, with a particular emphasis on prioritizing reforms targeted at reducing clinical documentation burdens. 

Key WHA recommendations to HHS for policy change included:

• Review, simplify and update regulations and guidance regarding documentation requirements necessary to meet Medicare and Medicaid payment requirements 
• Revise regulations and/or create regulatory safe harbors that will permit discrete data gathered by the EHR—as opposed to narrative notes—to satisfy Centers for Medicare & Medicaid Services (CMS) payment requirements 
• Revisit and revise regulations and guidance that discourage physicians from delegating or incorporating clinical documentation to/from other staff and clinicians 
• Explore regulatory changes to HIPAA to leverage EHR systems to standardize prior authorization processes and reduce associated documentation burdens
• Update Medicare Advantage and Medicaid managed care organization rules and contracts to drive commercial payer adoption of clinical documentation simplification and standardization reforms
• Continue and accelerate work to reduce EHR-related burden associated with CMS program reporting
• Focus future interoperability initiatives on care delivery systems that lack robust EHR usage and/or are highly fragmented
• Improve standardization and interoperability of public health and prescription drug monitoring program systems
• Encourage HHS to develop and advance metrics to monitor the impact of their strategies to reduce clinician EHR burden