Premier submits comments on proposed EHR “meaningful use” rule

March 12, 2010

Premier today urged the Centers for Medicare & Medicaid Services (CMS) to modify the proposed rule on the Medicare and Medicaid electronic health records (EHR) incentive program to ensure that hospitals and other healthcare providers can reasonably achieve “meaningful use” of EHRs and qualify for the incentives.

In its comments submitted today to CMS, Premier strongly cautioned the agency that it will be impossible for a substantial number of eligible providers to qualify for EHR incentives in the first stage of implementation if they are required to comply with every one of the proposed rules’ criteria in the first stage of implementation to achieve meaningful use. Premier urged CMS to abandon this approach and set a lower threshold regarding the number of criteria an eligible provider must meet in the initial phase of implementation to qualify as a meaningful user of EHRs.

Premier also told CMS in its comments that eligible hospitals with multiple inpatient facilities operating under one provider number should receive EHR incentives for each inpatient facility. The rule, as proposed, would allow only one Medicare incentive base payment per year for multiple inpatient facilities operating under the same Medicare provider number. By contrast, an identical hospital whose inpatient facilities each operate under its own Medicare provider number would receive an annual $2 million for each facility. Premier underscored that multi-campus hospitals will incur separate EHR costs for each inpatient facility and that each facility should receive a separate base payment.

In its comments, Premier also expressed concern that timely compliance with the many new clinical quality measures in the proposed rule will be extremely difficult, and perhaps impossible, because existing EHR technology does not provide the necessary functionality to meet the requirements concerning these clinical quality measures. Premier recommends that quality reporting measures should not be imposed until the second stage of EHR implementation and only after issues that Premier has identified are addressed.

The Senate acted today to address another major concern that Premier raised in its comments, which is the need for CMS to modify the proposed rule to expand the eligibility for EHR incentive payments to physicians who work in hospitals. As proposed, the rule would prohibit EHR incentives for every eligible professional who furnishes substantially all of his or her covered services in any hospital setting, even if the provider does not use a hospital EHR system in providing those services. The Senate passed earlier today a jobs/tax extenders package (H.R. 4213) that includes Premier-recommended language which ensures that hospital-based providers who practice in hospital-owned outpatient centers and clinics qualify for the incentives.

www.premierinc.com

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