The coalition also asked for more time to meet the requirements, less burdensome reporting requirements and better harmonization between the separate Medicare and Medicaid EHR subsidy programs.
The American Recovery and Reinvestment Act of 2009 spells out that to qualify for EHR reimbursement payments, estimated to range between $14 billion and $27 billion, providers must use independently certified EHR systems for, at a minimum, electronic prescribing, the exchange of information to improve the quality of patient care and to report quality measures of the secretary's choosing to HHS. Congress also gave the Health IT Policy Committee, an advisory panel created under the stimulus law, broad latitude to make recommendations to HHS on additional meaningful-use criteria.
Last December, the CMS, which will administer the EHR subsidy programs, issued a proposed rule on meaningful use that went well beyond the three congressionally mandated minimums.
“The proposed rule takes an “all-or-nothing” approach, where failure to meet any one of the requirements means the provider will not receive an incentive payment,” according to the letter. “This approach does not acknowledge that providers have made enormous progress in creating and maintaining EHRs to improve patient care and safety. The inflexible sets of 23 and 25 requirements would result in very few providers being able to meet the all-or-nothing approach, despite having adopted numerous EHR components.”
The CMS is expected to produce a final rule on meaningful use by late spring. The first “payment year” under the Medicare portion of the EHR subsidy program, which is expected to be the largest, is scheduled to begin Oct. 1.
A copy of the letter is posted on the AHA website.