AMCNO Submits Comments to CMS on Meaningful Use (MU)

On January 13, 2010, the Centers for Medicare and Medicaid Services (CMS) published the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs Notice of Proposed Rule Making (NPRM). Over the past two months, the physician leadership and staff of the AMCNO have been evaluating and reviewing the proposed rule. CMS is charged with ensuring that physicians are a key component of the effort under the American Recovery and Reinvestment Act of 2009 (ARRA) to promote health information technology and its use to transform medical practice and the health care delivery system. Our comments focus on our support for a program that allows as many eligible physicians as possible to participate and that creates trust and buy-in from physicians on the value of that participation and the fairness of the process. 

After a detailed review and discussions with physicians and institutions from across the region, the AMCNO has prepared and submitted comments on the rule. Our comments focused on four specific areas of the rule including: The Academy of Medicine of Cleveland & Northern Ohio made four key recommendations to CMS as follows: 

  • CMS should limit the definition of hospital-based professionals ineligible to participate in the EHR incentive programs to ensure broad physician participation in Meaningful Use. 

  • CMS should scale back the measures, make the thresholds for the objectives and quality metrics more realistic, and allow achievement of meaningful use on something less than an “all or nothing” basis. 

  • CMS should allow eligible professionals to demonstrate meaningful use through substantial compliance with the measures and objectives in Stage 1. 

  • CMS should streamline that administrative burden on physicians so that physicians can easily create the compliance documentation needed.

A complete copy of the letter may be viewed at the following link: click here. An overview of the AMCNO comments will also be highlighted in our next issue of the Northern Ohio Physician magazine.