Testimony In Support of Proposed Changes to EHR-Meaningful Use Regulations

Submitted To the Board of Registration in Medicine

Re; 243 CMR 2.01(4), 2.02 and 2.06

Submitted by Richard S. Pieters, M.D.  MMS President

As president of the Massachusetts Medical Society, I wish to go on record in supporting our comments presented by our Vice-President Jim Gessner, M.D. My schedule does not allow me to be in Wakefield for the hearing, but I want to express that the proposed regulations are of utmost importance to the current and future patients and physicians of Massachusetts. The MMS strongly endorses the regulations as drafted, and the work the Board members and staff have done to understand the background of this legislation and to create regulations which will have a positive impact on care in the Commonwealth.

The Massachusetts Medical Society has a long history of involvement with electronic medical records. We have a Committee on Information Technology and other committees that look at the impact on clinical practice of developing technologies. As we review the experiences of our members and the literature on the impact of electronic medical records systems, we are becoming increasingly concerned that electronic medical records may not always meet the expectations that both clinicians and policy makers anticipated a few years ago.

Legislative mandates setting conditions for medical licensure have increased over the years. The MMS is concerned that such mandates often are adopted without debate , much less a detailed consideration of the evidence or a cost benefit analysis.

Evidence and anecdotes are starting to accumulate that many electronic medical records systems are not performing as anticipated and that the impact of the use of computers during and following primary care visits may have unintended consequences on the physician patient relationship and clinical outcomes.

The Institute of Medicine, in its report from Nov. 2011, Health IT and Patient Safety: Building Safer Systems for Better Care, finds that there are clearly some benefits to well-designed systems, particularly in the area of medication errors but poorly designed health IT “can crate hazards in the already complex delivery of care.” [i]

In a 2011 Pediatrics article,  “Legal, Ethical, and Financial Dilemmas in Electronic Health Record Adoption and Use”, the authors call for a national forum for key stakeholders to identify and find solutions for legal, ethical and financial dilemmas inherent in EHR’s [ii]. 

Just last year, a Task Force from the American Medical Informatics Association was formed “In response to mounting evidence that use of electronic medical record systems may cause unintended consequences, and even patient harm”.

These articles are just a small indication that the integration of electronic medical records into good clinical care is constantly evolving and the subject of enormous investment of resources by many of our most talented and dedicated physicians and researchers. All practicing physicians are actively interacting with electronic records and clinical information in many ways. However, systems are a work in progress which does not warrant a one size does not fit all, however.

As physicians we live the concept of first do no harm every day. The physicians of Massachusetts and our patients are depending on the Board to do the same and to implement the proposed regulations in a manner that supports clinical care without destroying physician patient relationships.

Thank you for your consideration.  


[i] Citation: Institute of Medicine (IOM). Health IT and Patient Safety: Building Safer Systems for Safer Care. Washington, DC: The National Academies Press, 2012.

[ii] Citation: Sittig DF, Singh H. Legal, ethical, and financial dilemmas in electronic health record adoption and use. Pediatrics 2011;127:e1042–7.

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