“It will be impossible for a substantial number of eligible providers to qualify for EHR incentives in the first stage of implementation if they are required to comply with every one of the proposed rules’ criteria in the first stage of implementation to achieve meaningful use,” writes the Primer health alliance, a large healthcare purchasing network, in its comment letter to CMS.
Premier urged CMS to abandon this approach and set a lower threshold regarding the number of criteria an eligible provider must meet in the initial phase of implementation to qualify as a meaningful user of EHRs.
Premier also told CMS in its comments that eligible hospitals with multiple inpatient facilities operating under one provider number should receive EHR incentives for each inpatient facility. The rule, as proposed, would allow only one Medicare incentive base payment per year for multiple inpatient facilities operating under the same Medicare provider number. By contrast, an identical hospital whose inpatient facilities each operate under its own Medicare provider number would receive an annual $2 million for each facility. Premier underscored that multi-campus hospitals will incur separate EHR costs for each inpatient facility and that each facility should receive a separate base payment.
In its comments, Premier also expressed concern that timely compliance with the many new clinical quality measures in the proposed rule will be extremely difficult, and perhaps impossible, because existing EHR technology does not provide the necessary functionality to meet the requirements concerning these clinical quality measures. Premier recommends that quality reporting measures should not be imposed until the second stage of EHR implementation and only after issues that it has identified are addressed.