ABC Submits Comments to CMS on the Medicare Stage 2 Electronic Health Record Incentive Program Proposed Rule for their Clients
Anesthesia Business Consultants, LLC (ABC) embraced a new role and filed formal comments on a “Notice of Proposed Rulemaking” with the Centers for Medicare and Medicaid Services (CMS) on May 7, 2012. The Proposed Rule 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.
Even with the best of intentions and a reasonable amount of funds to invest, very few, if any, anesthesiologists can qualify for the bonus incentives—but they may nevertheless be subject to the penalties. To earn the former and avoid the latter, a physician must comply with a set of 15 (17 in Stage 2) objectives and measure, plus 5 out of 10 additional “optional” measures (3 out of 5 in Stage 2), plus 6 (12 in Stage 2) Clinical Quality Measures. The vast majority of these objectives and measures were designed for the primary care physician and setting. 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 urges CMS to create this exception so that anesthesiologists will not be unfairly penalized.
At the same time, ABC has urged CMS to ensure a mechanism for the few anesthesiologists who can comply with the objectives and measures to report that they have in fact made meaningful use of certified EHR technology.
ABC’s integrated software platform, OneSourceAnesthesia, interfaces with many different EHR technologies, and we have partnered with a global technology company whose anesthesia EHR appears to be the most effective and efficient for anesthesia practices. We expect to undertake additional activities in our new role of advocating directly that Medicare consider the needs and interests of anesthesiologists, pain medicine physicians, and their patients.
If you have any questions or would like additional information please call 517-787-6440 x 4113, send an email to info@anesthesiallc.com, or visit our website at www.anesthesiallc.com.