Electronic Health Record Association’s blog
September 14, 2016
As we generally do with proposed regulations that impact EHR developers and their customers, the Electronic Health Record Association (EHRA) carefully reviewed and collectively commented on CMS’s proposed rule on the Hospital Outpatient Prospective Payment Systems (HOPPS) and EHR Incentive Program on September 1. Our comments, submitted on September 1 and available here, are based on the collective experiences of more than 30 EHRA member companies who service the vast majority of hospitals and ambulatory care providers using EHRs across the United States.
We put forth two key positions. The first centers around advocating for program alignment across Medicare and Medicaid requirements, as well as the EHR incentive programs with the Merit-Based Incentive Payment System (MIPS). The second states strongly that changes to the EHR incentive program at this late date relative to the current or next reporting period lead to costly and negative repercussions. We strongly recommend that CMS make every effort to incorporate the comments received up to and including this comment cycle in future rulemaking, in order to set appropriate and achievable requirements and deadlines to reduce the need for mid-year revisions.
June 28, 2016
Recognizing the complexity of the MACRA legislation, the Association expressed appreciation that CMS considered a variety of comments from a diverse set of stakeholders in developing the proposed rule. In their detailed comments, they emphasize that some of the complexities in the proposed rule will lead to many significant changes and implications for eligible clinicians.
June 28, 2016
On June 7, 2016, the EHR Association sponsored a briefing for Congressional staff engaged in crafting proposed legislation that addresses interoperability. EHRA member company, Allscripts, invited their client Stephen Nuckolls, CEO of Coastal Carolina Health Care (New Bern, North Carolina, U.S.A.), to participate as a panelist, along with four other healthcare provider organization executives.
May 7, 2016
With the accelerated adoption of electronic health records (EHRs), there is growing recognition of the benefits associated with the use of these technologies – reduced medical errors, faster access to complete information, more efficient communications among busy clinicians, and increasing patient engagement in their healthcare decisions. At the same time, there is a dialog taking place among all stakeholders on the issues related to busy clinicians taking advantage of data re-use capabilities to avoid re-entering identical information as they create their encounter documentation.
The EHR Association strongly believes that data re-use tools are critically important for clinicians, provide clear benefit for patients and, when used appropriately, enable accurate legal and financial recording workflows for providers.
February 10, 2016
When it comes to alternative payment models (APMs), organizations often ask “is it better to be a Medicare Shared Savings Program (MSSP) Track 1 Accountable Care Organization (ACO) or a Patient-Centered Medical Home (PCMH)?” Typically, the answer depends on a few factors: organizational goals, level of readiness to adopt new delivery models, and the mix of public and private payer incentive programs. Going forward, however, the newest factor that organizations must consider is how they want to be scored under the incentive programs created by the Medicare Access and CHIP Reauthorization Act (MACRA). As the Centers for Medicare and Medicaid Services (CMS) prepares to release the proposed rule for MACRA, the agency has made it clear that not all organizations participating in APMs will be considered “eligible” for purposes of the law’s APM incentive program. The statute requires that eligible APMs, those which qualify for the APM bonus payment, have the following characteristics:
December 16, 2015
CMS and ONC are considering tying the new Alternative Payment Models (APM) being designed per the MACRA legislation to prescriptive criteria for “use” of certified EHR technology, and considering development of new certification criteria specifically created for APMs. In doing so, do they risk going beyond congressional intent for the APM program and stifling innovation by imposing requirements on health IT beyond what is sought in the market, perhaps pursuing a strategy that may not be the best way to accomplish their end-goals – the rapid shift to value-based reimbursement and more integrated care?
December 2, 2015
Few, if any, health care payment and delivery initiatives underway promise to have as much impact on the nation’s shift from volume to value-based reimbursements, holistic clinical delivery, and overall system sustainability as the Medicare Access and CHIP Reauthorization Act (MACRA).
By establishing distinct and relatively complex delivery and payment tracks – the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs) – programmatic vigilance and collaboration is needed by all healthcare stakeholders.
November 15, 2015
In October, we provided comments to ONC on its April 2015 “Report on Health Information Blocking”, in the spirit of collaborating to establish an environment where the right data can flow to the right party at the right time using a set of agreed-upon standards. While some press coverage characterized our comments as negative (“…Prove It”), we in fact attempted to provide balanced feedback, recognizing that the first challenge is to come up with a definition of “information blocking” that everyone agrees on.
We clarified that charging for interface software and services should not be considered information blocking, as there are real costs incurred by EHR developers and other health IT companies in building and maintaining interfaces. In the EHRA response, we reiterated our support for a standards-based approach to connectivity which, over time, can reduce these costs. But we also pointed out that there are a large number of stakeholders – e.g., public health agencies – which are not compelled to use the same standards; until they are, systemic costs will continue to be higher than necessary.