51 Healthcare Groups Call for Changes Of Federal EHR Adoption Proposal

The groups also are asking for a less-restrictive definition of hospitals. Of concern is CMS's proposal to use Medicare provider numbers to distinguish hospitals for EHR incentive payment purposes. "There is no standard approach to exactly which facilities a Medicare provider number encompasses and, in many hospitals, a single provider number can include multiple sites of a hospital system," say the healthcare organizations.

The groups are therefore calling CMS to define a hospital "as a discrete facility of service, so that individual sites of hospitals are eligible to separately qualify for the incentives." Since CMS does not currently collect data by individual hospital sites, it would have avenues by which it could do so—such as through cost reports.

The organizations also are calling for less burdensome reporting requirements on providers. To do this, they are asking for CMS to require reporting of only "HIT functionality measures that can be generated directly from EHRs"—with no need for manual chart reviews. Also, they say CMS should postpone requirements on quality metric submissions until the "means to capture the data from EHRs and submit the data to CMS is validated."