The proposed high bar for hospitals to receive incentive payments for meaningful use of electronic health records is unrealistic and will limit their ability to get the payments, according to the American Hospital Association.

The Chicago-based organization in its formal comment letter to the Centers for Medicare and Medicaid Services calls for an incremental and flexible plan that will enable more hospitals and physicians to achieve meaningful use. "Our goal is not to slow down progress toward fully functional EHRs," the letter states. "Rather, we think our approach will lead to much broader adoption rates of successful EHR systems across the vast majority of hospitals in a sustainable timeframe because hospitals would have more certainty, predictability and flexibility to address both institutional and local community priorities."

A January survey of nearly 800 hospital respondents found less than one percent could meet all 23 criteria for meaningful use in the proposed rule, the AHA notes. The bottom line, according to the association, is that CMS' proposed "all-or-nothing" approach to meaningful use and very short timeframes are unrealistic.

The AHA recommends modifying proposed meaningful use objectives and adding 12 additional objectives, and enabling hospitals to show meaningful use by meeting 25% of objectives in 2011 or 2012 with increased percentages in future years. The association also asks for changes in the definitions of a hospital and a hospital-based eligible professional, and asks for inclusion of critical access hospitals in the Medicaid incentive program.

The full 81-page letter, including a three-page summary at the beginning, is available at

--Joseph Goedert

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