Plenty of multicampus hospitals have a beef with the latest CMS rule on the federal electronic health-record system subsidy program, but theirs is a problem only an act of Congress can solve.
Irked by CMS rule quirk
IT subsidies cut by provider-number provision
The consensus among industry leaders for the aggrieved hospitals is that CMS rulemakers had a solid legal peg on which to hang their disappointing interpretation—that multicampus hospitals using one Medicare provider number are ineligible for the same level of federal EHR subsidy payments as similar organizations in which each hospital has its own Medicare provider number.
“In a sense, the administration, in printing the final rule, has spoken,” said Chip Kahn, president of the Federation of American Hospitals. “Their view and that of the general counsel at HHS is reflected in that.” Kahn said each of the 22 for-profit hospital corporations that make up the federation have at least a few hospitals affected by the quirk in the federal EHR subsidy program. Several members have many.
The interpretation came in a final rule issued July 13 that establishes meaningful-use criteria and procedural guidelines for EHR subsidies under the American Recovery and Reinvestment Act of 2009 (July 19, p. 6). Under that rule, hospitals that use one Medicare provider number for all campuses qualify for only a single $2 million “base payment.” Meanwhile, systems that use multiple provider numbers could qualify for multiple base payments. A second portion of the Medicare EHR subsidy payment is based on patient volume, with $200 paid per discharge, beginning at 1,150 discharges and capped at 23,000.
Randy Thomas, vice president of product strategy and planning for Premier, said as many as 50 of its hospital customers are affected by the exclusionary policy. The maximum amount a system can receive under the federal IT subsidy scheme is about $11 million per hospital. Conceivably, a five-hospital system could receive as much as $55 million if all five have their own Medicare provider numbers, while a five-campus hospital with only one number would get only $11 million.
Greg Kall, vice president and chief information officer at two-campus Summa Health System in Akron, Ohio, said 486-bed Summa Akron City Hospital and 101-bed Summa St. Thomas Hospital have been live with EHR systems for five years. “What it means for us is a decrease in payment of about $2 million,” he said.
“To me, it's an arbitrary distinction,” Kall said. “The vendor community charges me incrementally fees for both facilities. The costs that you have deploying a system don't change with having a provider number.”
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