The Premier healthcare alliance has submitted its comments in response to the Stage 2 Electronic Health Record (EHR) Incentive Program proposed rule, announced in February by the Centers for Medicare & Medicaid Services (CMS). While the for-profit stakeholder collaborative organization supported CMS’ decision to extend Stage 1 through 2013, it encouraged CMS to publish a final rule specifying Stage 2 requirements no later than August 2012.
According to Premier, failure to publish a final regulation by August 2012 “would seriously compromise the ability of the healthcare community to meet Stage 2 requirements beginning in 2014.” The organization says if CMS is not able to accomplish this, they recommend Stage 1 be continued for an additional year, and that Stage 2 commence in 2015.
Other than that, Premier made a comment on multi-campus hospitals, urging CMS to modify hospital eligibility requirements to ensure these institutions are not prevented from earning incentives through the EHR Incentive Program for each inpatient facility. They also urged to make changes for several hospital objectives and measures to ensure appropriateness for eligible hospitals (EHs) and critical access hospitals (CAHs).
Also, along with recommending changes to the menu set of objectives and measures, Premier expressed its concern about the risk that many hospitals would unable to meet the required two of four available measures. They asked CMS to carefully assess whether the menu set it intends to finalize is one that will include a sufficient number of feasible measures for the typical hospital.
There were other concerns from Premier, regarding clinical quality measure reporting, payment adjustments, and expectations for payment adjustments. Here is an entire list of Premier’s comments.