The Premier Inc. provider alliance has added its voice to the growing chorus that the proposed rule setting criteria for incentive payments for meaningful use of electronic health records is too ambitious.

"Our overarching concern regarding the NPRM is that it establishes a number of requirements and restrictions that are diametrically opposed to accomplishing the HITECH Act's goal of implementing a nationwide HIT infrastructure in a timely manner," states Premier's comment letter to the Centers for Medicare and Medicaid Services. "It is clear the HITECH Act is designed to infuse substantial funds into the economy so as many eligible providers as possible can rapidly implement functioning EHRs to serve as the backbone for the nation's HIT infrastructure. Congress recognized that most eligible providers would require EHR incentives quickly in order to actually get their EHR projects off the ground."

A provider qualifying as a meaningful user in Stage 1 should not require the satisfying of 100% of criteria, Premier contends. "We are concerned it will be impossible for a substantial number of eligible providers to qualify for EHR incentives in Stage 1 if they are required to comply with every one of the NPRM's proposed Stage 1 meaningful use criteria. The reality is that many eligible providers have not even begun planning for EHR implementation because they simply have not had the funding or personnel necessary to consider such a project."

Further, the criteria as proposed would require providers without EHRs to accomplish within 14 months what other providers have taken many years to accomplish as they adopted EHRs, according to Premier.

The organization does not propose a particular percentage of meaningful use criteria to be met in order to receive incentive payments, other than the threshold should be "substantially" less than 100 percent. "We believe CMS will be in the best position to set a reasonable Stage 1 compliance threshold after its review and analysis of all comments submitted regarding the NPRM."

That said, Premier did ask CMS to take into account five specific factors when setting the threshold. For Premier's full 42-page comment letter, click here.

--Joseph Goedert

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