The rule would implement the accounting for disclosures provisions of Section 13405 of the HITECH Act. HITECH expands the privacy rule's disclosure requirements by including disclosures during the previous three years for treatment, payment and health care operations if a covered entity uses an electronic health records system. During a public comment period in 2010, the Medical Group Management Association called the requirement burdensome and unrealistic.
"The fact that HITECH stipulates that the TPO accounting is only required for those physician practices that have adopted an EHR suggests that the government believes TPO disclosures would be collected and stored on this one clinical system," according to MGMA's letter. "This is simply not the case. The majority of physician practices store their clinical data in an EHR and their administrative data (including payment information and data that would quality as 'health care operations') in their practice management system. Satisfying an accounting for TPO request in most practices is not a simple keystroke strike. As discussed more fully below, MGMA members have made it clear that completing these types of reports requires a substantial amount of manual collection from multiple data sources."
--Joseph Goedert
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