May 9, 2012

For the first time in its 32-year history, Anesthesia Business Consultants, LLC (ABC) has filed formal comments on a “Notice of Proposed Rulemaking” published by the Centers for Medicare and Medicaid Services (CMS). The Proposed Rule in question would modify the requirements for physicians and hospitals to demonstrate “meaningful use” of certified Electronic Health Record (EHR) technology. Meaningful users of certified EHRs are able to earn Medicare bonuses of up to $44,000 or Medicaid bonuses of up to $63,750 per physician. Just as important, eligible professionals who fail to become meaningful users will be subject to payment penalties beginning in 2015.

The objectives and the associated performance measures that physicians must meet, in order to earn the incentive and to avoid the penalty, are designed for primary care. The addition of a few specialty care measures for Stage 2 of the Program does not help anesthesiologists, who would have to change their clinical practice in many unhelpful respects in order to demonstrate meaningful use. The proposal for a new exception from the payment penalty, therefore, for physicians who have minimal consultative or follow-up encounters with their patients and who have little influence over the EHR technology selected by their hospitals, is very important. ABC’s comment letter to CMS focuses on the necessity for this exception.

At the same time, ABC has urged CMS to ensure a mechanism for anesthesiologists to report that they have in fact made meaningful use of certified EHR technology in the rare cases where they might be able to do so.

ABC provides practice management and billing services to more than 350 anesthesia groups across the country. The majority of the more than 8,000 individual providers in those groups use Health Information Technology to a greater or lesser extent. Over the past year ABC has developed an integrated software platform, OneSourceAnesthesia, that interfaces with EHR technology, and we have partnered with another company whose anesthesia EHR appears to be the most effective for anesthesia practices. Client interest in HIT is strong and ABC is proceeding quickly to meet their various needs—including, as of now, the need to communicate with the government when clarification of an issue would protest the interests of our clients and their patients.