Healthcare organizations applauded several provisions of the Centers for Medicare & Medicaid Services' proposed physician fee schedule for 2015, such as reimbursement for telehealth and chronic care management, but were not enthused about the agency's' suggestions about electronic health records and the Meaningful Use program.
The American Hospital Association (AHA) was in favor of reimbursing physicians for chronic care management, but not the proposed requirement that the physicians use EHR technology certified to the most recent version of certification, and suggested that such a requirement be delayed for three years.
"It is very likely that there are physician practices that effectively coordinate patient care but have not yet fully implemented a certified EHR; in particular, not all types of physicians have access to certified EHRs that are a good fit for their specialty practice. And as CMS well knows, many physicians are still struggling to meet meaningful use requirements," Linda Fishman, AHA's senior vice president of public policy analysis and development said in comments submitted to CMS.
The American Medical Association (AMA) noted that CMS' proposal that eligible professionals (EPs) would not have to recertify to the most recent version of electronic specifications for clinical quality measures (CQMs) would not be useful, since EPs needed to use CEHRT for the other Meaningful Use objectives. The AMA also recommended that measure ACO-11, which requires ACOs to have a percent of primary care physicians who successfully qualify for Meaningful Use incentive payments be dropped since it has no direct relationship to the quality of patient care.
The AMA additionally was not in favor of CMS' proposal that if an error were found in the e-CQMs, that the physician quality reporting system (PQRS) simply use the older version.
"CMS is essentially suggesting that a version of the measure that is no longer supported should be implemented which is inconsistent with program goals," AMA's CEO James Madara said in his comments. "Reverting back to an older version of a measure will requires users of the measures, including EPs and EHR vendors, to support two versions of a single standard [e.g., HQMF, QDM], thus increasing the burden on these stakeholders and creating the possibility for substantial confusion and errors."
The College of Healthcare Information Management Executives and the Association of Medical Directors of Information Systems (AMDIS) also jointly expressed concerns about CMS' proposed changes to eCQMs, as did HIMSS.
CMS has been using provider fee schedules to introduce new EHR requirements and tweak the Meaningful Use program, both for providers who are eligible to participate and for those who can't participate in the program.
Comments on the proposed rule, which was published in the July 11 Federal Register, were due Sept. 2.
To learn more:
- here are CHIME's comments (.pdf)
- here are HIMSS' comments (.pdf)
- read AHA's comments (.pdf)
- check out AMA's comments (.pdf)