As federal agencies start to confront President Obama's January 18 executive order to reduce regulatory burdens, the Centers for Medicare and Medicaid Services is getting an earful from the American Medical Association.

In a nine-page letter to CMS Administrator Donald Berwick, M.D., the AMA agues against overly burdensome regulations covering such areas as unfunded mandates, physicians consultations, incompatible incentive programs, inconsistent audit policies, administrative simplification, medical enrollment processes, Physician Quality Reporting System feedback reports, education and outreach, and nursing home pain management.

"For example, the quality reporting measures established under PQRS vary from those physicians must meet in order to be a 'meaningful user' of a certified EHR under Stage 1," the AMA notes. "This is not required and we urge CMS to align the quality measure requirements for both of these programs to reduce the reporting burden on physicians."

The Medicare e-prescribing incentive program also conflicts with meaningful use requirements, which could require physicians to purchase a standalone e-prescribing system this year, then discard it for a certified EHR in 2012 just to avoid an e-prescribing penalty, the AMA contends. "Further, CMS' own outreach and education for the past year made it clear that physicians were not permitted to participate in both the e-prescribing and EHR programs so many physicians continue to believe they may only participate in one of these programs when in fact they must participate in both simply to avoid an e-prescribing penalty."

The AMA asks CMS to create a unique plan identifier to ease the gathering of all information needed to process claims, and to use a single contractor to oversee both the existing Medicare and the health reform-mandated Medicaid National Correct Coding Initiative edits. The AMA "is deeply concerned that CMS' current plan for implementing NCCI in Medicaid will result in the use of two different NCCI edit contractors," according to the letter. "This is likely to lead to inconsistencies between Medicare and Medicaid, further complicate a landscape that is already littered with competing claims edit programs and subvert the ACA's and the President's goal of administrative simplification."

Full text of the AMA letter to CMS is available here.

--Joseph Goedert


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