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  • HIVMA Comments on CMS Proposed Rule: Electronic Health Record Incentive Program

    In a letter to the Centers for Medicare & Medicaid Services (CMS) Acting Administrator, HIVMA's Chair-elect, Kathleen Squires, MD, offered the following comments in support of the proposed rule:

    "The proposed rule is important to HIV medicine, considering that 40% of our HIV patients rely on Medicaid and nearly 20% rely on Medicare programs for their health care coverage. As proponents of the use of health information technology to improve the quality and coordination of HIV medical care and control costs, we urge the administration to simplify the meaningful use criteria and incentive payment qualifying requirements in order to ensure the success of the program among HIV providers. Unless significant changes are made and timelines reexamined, many HIV safety net medical providers will likely have difficulty meeting the proposed standards, making them ineligible for this important funding, and subjecting them to Medicare reimbursement rate penalties for noncompliance. In developing the final rule, we urge you to consider the following recommendations:

    • As presently structured, the EHR incentive program will favor larger, better-funded practices and early adopters.
    • Reporting requirements and data systems must be streamlined across federal programs to eliminate redundancy and maximize efficiencies with limited program, IT and data management resources.
    • The proposed requirements for demonstrating meaningful use of EHRs may be overly burdensome and needlessly complex for some practices, which could discourage physician participation in the program, especially among safety net clinicians.
    • Clinical quality measures to be reported must include those that are applicable to the patients and conditions HIV physicians treat.
    • Clinical quality measures focused on preventive care should be expanded to include HIV and STD screening.
    • The capabilities and functionalities of EHR systems should support coordination of care through the patient‐centered medical home model, which requires reform of reimbursement incentives.
    • Meaningful use objectives 22 - 24 that rely on patient level information being transferred between entities (laboratories to office, hospital to office, office to office) will be problematic in the absence of a clear legal and policy framework dictating the exchange of clinical data under the HIPAA."

    Read the full comments [PDF]  PDF

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