The federal government will miss a huge opportunity to advance use of electronic health records if it continues on an "all or nothing" approach to meeting "meaningful use" criteria to qualify for incentive payments from Medicare and Medicaid, according to the American Academy of Family Physicians.
In a comment letter to the Centers for Medicare and Medicaid Services on the meaningful use proposed rule, the association expressed great concern that many eligible providers won't be able to achieve all criteria by 2011 or 2012. "The AAFP does not want to discourage practices who cannot achieve 100% of the requirements from using, improving or implementing EHRs simply because they will receive no incentive for anything less," according to the letter. "We strongly believe that offering a partial incentive for partial Meaningful Use will vastly increase the number of eligible providers who will make the attempt to become meaningful users."
AAFP recommends consideration of parity between the first year requirements for Medicare and Medicaid incentives. "Currently, the rule permits incentive payments be made in the first year for acquisition of certified EHR technology to physicians who meet the Medicaid eligibility requirements. A heavier burden of meaningful use attestation is imposed on physicians who meet the Medicare FFS program's requirements. We believe that consideration should be given to create parity in the first year between the two programs, allowing physicians in small and medium sized medical practices to receive incentive payment according to the Medicaid requirements for EITHER program, with attestation of meaningful use a requirement for payment in the second year."
The association also calls for primary care physicians and other ambulatory-based physicians in practices that are part of a hospital-based organization to be eligible for incentive payments. The proposed rule excluding them does not follow legislative intent, the association believes. To access AAFP's complete seven-page comment letter, click here.
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