BlueCross BlueShield of Illinois will pay the federal government and the state of Illinois $25 million to settle False Claims Act allegations, the Justice Department has announced.
The settlement resolves claims that BCBS IL illegally terminated coverage for private duty skilled nursing care for medically fragile, technologically dependent children, which shifted the cost of the care onto Medicaid, DOJ said in a statement.
Under the alleged scheme, children whose specialized care should have been covered by BlueCross BlueShield of Illinois were shifted to the government-funded Home and Community Based Services Medicaid program, operated by the Illinois Division of Specialized Care for Children.
The settlement also resolves claims that BCBSI denied patient claims based on internal, undisclosed guidelines that were more restrictive than the language provided to beneficiaries in plan policy materials. Additionally, the DOJ claimed that BCBSI improperly told policy holders that children were not covered for private duty nursing during the claims review process sought after denials.
Under the agreement, BlueCross BlueShield of Illinois will pay $14.25 million to Illinois and $9.5 million to the federal government. The insurer, a division of Health Care Service Corp., will also pay $1.25 million to Illinois under the state consumer fraud statute.
"It is appalling for a major insurance company to terminate medical services coverage for sick children in need just to boost their bottom line at taxpayers' expense, as we've alleged here," said Tony West, Assistant Attorney General for the Justice Department's Civil Division. "When private insurance companies improperly force patients to turn to Medicaid for medical coverage those companies should be providing, we will hold them accountable."
BCBS IL issued the following statement: "Our agreement with the state attorney general and the federal government resolves a long-standing dispute concerning certain claims involving private duty nursing benefits. While we disagree with the allegations and deny any inappropriate conduct at any time, we are pleased to put this matter behind us and focus on serving the needs of our policyholders. This dispute began many years ago when we reviewed certain claims and determined that the benefits sought were not covered by the applicable insurance plans and policies. These plans and polices determine which benefits are covered and which are not. Several years ago, in cooperation with the state attorney general, we expanded our explanation of benefits to ensure that our members understood what nursing benefits are covered under their plans. That action, coupled with today's agreement, are in the best interests of our members."
DOJ has used the False Claims Act to recover more than $5.5 billion since January 2009 in cases involving fraud against federal healthcare programs. The Justice Department's total recoveries in False Claims Act cases since January 2009 are nearly $7 billion.
The Department of Health and Human Services said Thursday it is making available nearly $200 million in grants to help states combat "unreasonable premium increases" of 10% or more.
HHS said the new money will bolster state programs to improve transparency and thoroughness in the review process for health insurance premium rate hikes, and builds on the $46 million awarded last August to help 45 states and the District of Columbia crack down on unreasonable premium hikes. The grants will help states with new federal rules under the Affordable Care Act that proposed in December to require insurance companies to publicly justify unreasonable premium rate increases, HHS said.
"For too long, families and small business owners have struggled to pay ever increasing health insurance premiums," said Steve Larsen, director of the Center for Consumer Information and Insurance Oversight, which administers the rate review grants. "The Affordable Care Act provides States new resources and tools to curb those rising costs, as well as to help make sure that consumers and businesses are getting value for their premium dollars."
Of the total funding, $149 million is available to states for baseline grants to improve transparency and effectiveness in rate hike review. Another $50 million in grant funds are available to states as either: "workload" grants totaling $22.5 million for states with larger populations and more health insurers; or "performance" incentives totaling $27.5 million for states that have – or enact – the authority to approve or disapprove rate increases.
America's Health Insurance Plans and other insurance industry advocacy groups complain that the government has focused on healthcare premium increases while ignoring the underlying costs driving the increases.
Health plan leaders polled for HealthLeaders Media's Industry Survey 2011, cited "government laws and mandates" as a top driver of healthcare costs, second only to overutilization of services.
In a letter this week to HHS, Daniel T. Durham, AHIP's executive vice president for policy and regulatory affairs, warned that "politicizing the reviews…threatens to undermine the financial health and continued viability of health plans." Durham reiterated the health plans' contention that "strong steps outside of the rate review process (emphasis theirs)are needed to address the underlying factors that are driving medical costs. The rate review process cannot serve as a substitute for meaningful health care cost containment."
However, the nonprofit Consumer Union said the grant money is welcomed and needed.
"Right now, we have a patchwork of rate review rules and practices in the states. Even states that have authority to reject rate increases often lack the resources to collect sufficient data and closely analyze rate hikes," said Sondra Roberto, a staff attorney for Consumers Union. "An insurer's rate increase is always based on future projections of revenues and costs, so it is very important that these projections are analyzed to ensure that they are reasonable, fair, and based on valid data and assumptions. We hope that states receiving this funding will use it to improve data collection, standardize filing requirements, and conduct more in-depth reviews."
Roberto said states have a poor history of considering the impact of rate hikes on consumers, or of making the process open for consumer advocates. "These grants will hopefully encourage more states to open up the process to allow more public involvement and use this input to balance the hardship on consumers against the company's need for an increase," she said.
Whether or not Medicare patients undergo elective surgery depends on where they live and their doctors, according to a report from the Dartmouth Atlas Project and the Foundation for Informed Medical Decision Making.
Researchers found remarkably wide regional variations in elective surgery for Medicare patients even though they had similar conditions.
For example:
Men over 65 with early-stage prostate cancer in San Luis Obispo, CA are 12 times more likely to have surgery to remove their prostate than those in Albany, GA.
Medicare patients with heart disease in Elyria, OH were 10 times more likely to have a procedure such as angioplasty or stents than those in Honolulu, HI.
Women over 65 living in Victoria, TX were seven times more likely to undergo mastectomy for early-stage breast cancer than women in Muncie, ID.
“These striking variations are the by-product of a doctor-centric medical delivery system. In highlighting the variation from community to community for elective procedures, we hope to shine a light on the fact that patients’ preferences are not always taken into account when medical decisions are made,” says Shannon Brownlee, lead report author and instructor at the Dartmouth Institute for Health Policy and Clinical Practice.
The report is the first in a series looking at individual states and regions, and highlights Minnesota in addition to presenting national trends. Researchers analyzed the rates of elective or ?preference-sensitive? procedures, including:
mastectomy for breast cancer;
coronary artery bypass surgery;
percutaneous coronary intervention;
back surgery;
knee and hip joint replacement;
carotid artery surgery;
gall bladder removal;
radical prostatectomy for prostate cancer;
The report also advocates for shared decision-making to help patients understand their choices and share treatment decisions with their clinicians. The report also describes the treatment choices available for the preference-sensitive procedures, all of which can?but do not have to be? treated with surgery, as well as steps patients can take to make sure they get the care they want and need.
?All too often, patients facing elective surgery are not given an opportunity to learn about the full range of options, and that each choice has unique risks and benefits. Many are not even aware that the decision about an elective procedure is actually a choice. Instead, they routinely delegate such important decisions to their clinicians, with the result being that patients often do not get the treatment they would prefer,? says David C. Goodman, MD, report co-author and co-principal investigator for the Dartmouth Atlas Project, and director of the Center for Health Policy Research at the Dartmouth Institute for Health Policy and Clinical Practice.
The researchers explain that differences in clinicians? personal beliefs and opinions contribute to the variation in surgical rates in observed geographic locations. For example, there is considerable disagreement among surgeons about the need for back surgery, its effectiveness, and even the best way to diagnose the cause of back pain. With no consensus about how to diagnose and treat back pain, the rate of back surgery varies widely from place to place.
As a result, Medicare patients living in Casper, WY are nearly six times more likely to undergo back surgery than patients living in the Bronx, NY.
?Some of the most important choices in medicine are not the clinician?s alone to make. Patient preference is especially important when facing a test, surgery or treatment that is elective. In order to ensure that patients get the treatment that is right for them, the choice should be a shared decision. When done right, shared decision-making results in a better decision: a personalized choice based on both the best scientific evidence and the patient?s values,? says Michael J. Barry, MD, report co-author and president of the Foundation for Informed Medical Decision Making.
The Dartmouth Atlas Project is located at the Dartmouth Institute for Health Policy and Clinical
Practice and principally funded by the Robert Wood Johnson Foundation.
Click here for the full report, Improving Patient Decision-Making in Health Care: A 2011 Dartmouth Atlas Report Highlighting Minnesota.
Hospitals are spending billions of dollars to achieve meaningful use of electronic medical records, but if patients don't use the new technology, hospitals may not reap the federal stimulus payments that await.
That's the conclusion of a report -- Putting Patients into Meaningful Use – from PwC's Health Research Institute, which found that 14% of 1,000 consumers surveyed last fall said they get their medical records electronically from their physicians, and 30% of patients said they didn't know why they would need to.
Bruce Henderson, director and national leader of the EHR-HIE Practice at PwC says hospitals need to build in patient input earlier in the process to comply with Stage 2 of meaningful use requirements.
"Successful use of electronic health information will ultimately be measured in better patient outcomes, higher quality and reduced costs," Henderson said. "Health systems need to have both patients and physicians actively using the health information to make care decisions, and they aren't there yet."
Henderson said providers must first understand what healthcare consumers want before they can be sold on the benefits of EMR. "Then, they need to build new, technology-enabled healthcare delivery processes around patient preferences and convenience, which means changing how clinicians work," he said.
The PwC survey of 1,000 healthcare consumers found that:
Half of patients said they call their physician's office or hospital for a paper record, and 11% said they don't know how to get their health record.
Of those who access their medical record electronically, 34% share the information with primary care physicians and specialists.
While basic information about prescriptions and appointments are readily available to consumers who have electronic access to medical records, 55% can't access lab results or physician visit notes.
Only 13% of consumers said they'd been asked by providers what they think about EMRs, even though 56% said they'd be willing to talk about what they'd like in an EMR and how they'd like to use it.
When asked how they would like EMR to be used, 66% of consumers said for physicians to follow-up on their condition, 59% said for scheduling follow-up appointments, and 53% said to learn about treatment options.
35% of consumers said they would like their physician to use the information to monitor treatment compliance, and 34% said they would like their physician to monitor their health condition, such as blood pressure, remotely via a device that automatically sends information.
Approximately one-quarter of respondents would like to share electronic health information with family members to better understand family medical history.
13% of health leaders have an interactive patient portal in place, while
66% have a physician portal in place
HHS' Stage 2 proposed standards for meaningful use may require hospitals to offer 80% of patients with the ability to access to view and download their health information via a Web-based portal within 36 hours of discharge. Doctors and other providers must have at least 20% of their patient populations electronically accessing their health information, including access to diagnostic test results. Providers must meet these minimum requirements by October 2012 to qualify for additional stimulus money.
While 90% of more than 300 provider executives surveyed by PwC in the spring of 2010 said they expected to achieve meaningful use standards before the penalties kick in, their confidence is waning slightly as new realities set in and health organizations rethink their work plans to devote more attention on engaging external stakeholders. By the fall of 2010, 82% of the executives said they will meet the timetable.
Henderson said there are significant social, educational, and access barriers that providers are trying to overcome – including a gap in expectations between what patients and physicians want, and conflicting views about turnaround time. PwC's cited one hospital's internal research that found that physicians thought 45 days was a reasonable timeframe for making test results available electronically, while patients expected this information within 30 minutes.
"A patient's medical record and the health information within it should not be a history lesson. Those days are over," Henderson said. "To be meaningful, health information needs to be relevant, actionable, integrated into care and treatment decisions and available in real-time."
PwC's survey also found progress. Nearly one-third of health systems said they are now adding patient input into their meaningful use initiatives, up from 19% last spring. Approximately 50% of health systems are providing assistance to physicians who need support tools for using EMR in their clinical work.
The National Board of Medical Examiners has agreed to provide "reasonable testing accommodations" and remove other barriers for people with disabilities who want to take the U.S. Medical Licensing Examination, the Department of Justice has announced.
The agreement disclosed this week settles an Americans with Disabilities Act complaint that was lodged against the private, nonprofit NBME by Frederick Romberg, a Yale Medical School student with dyslexia who was twice denied "reasonable testing accommodations" to take the exam. With the settlement, Romberg will be given double the standard testing time and a separate testing area to take the USMLE.
"In the past, demands for unnecessary or redundant documentation, burdensome and expensive repeated professional evaluations, or irrelevant evaluative testing unrelated to the ability to demonstrate one's knowledge or skills on an examination prevented individuals with appropriately documented disabilities from pursuing their chosen professions." said Thomas E. Perez, assistant attorney general for DOJ's Civil Rights Division. "By entering into this agreement, NBME is doing its part to ensure that people with a reading disability like Mr. Romberg will have the opportunity to take the USMLE with the reasonable testing accommodations they need to demonstrate their knowledge and ability."
Under the agreement, the NBME will:
· Only request documentation about (a) the existence of a physical or mental impairment; (b) whether the applicant's impairment substantially limits one or more major life activities within the meaning of the ADA; and (c) whether and how the impairment limits the applicant's ability to take the USMLE under standard conditions;
· Consider the recommendations of qualified professionals who have personally observed the applicant in a clinical setting and recommended accommodations based upon their clinical judgment that the individual is substantially limited in one or more major life activities within the meaning of the ADA and needs the requested test accommodations in order to demonstrate his or her ability and achievement level; such recommendations are to be based on generally accepted diagnostic criteria and supported by reasonable documentation.
Consider all evidence indicating whether a person's ability to read is substantially limited within the meaning of the ADA, including the extent to which it is restricted as to the conditions, manner or duration as compared to the reading ability of most people.
DOJ pressed for the settlement under Title III of the ADA which prohibits discrimination against people with disabilities by private testing entities that administer examinations related to professional licensing.
In response to the settlement with Justic, NBME issued this statement:
"The NBME was first contacted by the Department of Justice regarding Mr. Romberg in October 2010. We explained to the Department of Justice the reasons for our decision on Mr. Romberg?s request for testing accommodations. Through the Department of Justice, NBME was provided additional documentation relating to Mr. Romberg, and NBME and the Department of Justice subsequently reached an amicable resolution that addressed the concerns of each party. The NBME will continue to provide testing accommodations to candidates in accordance with the requirements of the Americans with Disabilities Act. Our accommodation process is rigorous but fair, and properly reflects the important role that the USMLE plays in the licensure process for physicians. We appreciate having the opportunity to work with the Department of Justice toward a mutually satisfactory outcome."
Maryland-based Cignet Health has been slapped with a $4.3 million fine for its refusal to provide patients with copies of their health records, and for willfully failing to cooperate with the federal government's attempts to resolve the complaint, the Department of Health and Human Services announced Tuesday.
HHS's Office for Civil Rights said the fine is the first such "civil money penalty" imposed for violations of the Privacy Rule of the Health Insurance Portability and Accountability Act.
Calls to Mitchellville, MD-based Cignet on Tuesday afternoon were not immediately returned.
HHS's Office of Civil Rights said Cignet violated 41 patients' rights by denying them access to their medical records when requested between September 2008 and October 2009. The patients complained to OCR alleging that Cignet was violating the HIPAA rule that requires "covered entities" to provide patients with copies of their medical records within 30 days -- and no later than 60 days -- of the request, HHS said.
The civil money penalty for the violations was $1.3 million.
During the investigations, however, Cignet allegedly ignored OCR's demands to produce the records. A federal court issued a default judgment against Cignet on March 30, 2010. On April 7, 2010, Cignet gave the medical records to OCR, allegedly with no efforts to resolve the complaints through "informal means." OCR alleged that Cignet also failed to cooperate with the investigation from March 17, 2009, to April 7, 2010, indicating "Cignet's willful neglect to comply with the Privacy Rule." The failure to cooperate with OCR added $3 million to the civil money payment, HHS said.
"Covered entities and business associates must uphold their responsibility to provide patients with access to their medical records, and adhere closely to all of HIPAA's requirements," said OCR Director Georgina Verdugo. "The U.S. Department of Health and Human Services will continue to investigate and take action against those organizations that knowingly disregard their obligations under these rules."
The civil money penalty is based on the violation categories and increased penalty amounts authorized by Section 13410(d) of the Health Information Technology for Economic and Clinical Health (HITECH) Act.
Steward Health Care System, the physician-led operator of eight acute care hospitals in the Boston area, has expressed an "interest" in taking over Jackson Health System, Miami's financially troubled safety net hospital, in a deal that -- if completed -- would be valued at about $1.1 billion.
In a non-binding letter sent Monday to John Copeland, chairman of the Public Health Trust, which oversees JHS, Steward Healthcare CEO/ChairmanRalph de la Torre, MD, said he "envisions a transaction" under which SHC would assume JHC's approximately $500 million in outstanding debts, and invest another $600 million in capital and infrastructure improvements.
"Not only will this investment allow JHS to modernize its facilities and equipment, it will have the added benefit of creating economic activity that will mean thousands of additional jobs for the people of Miami-Dade County," de la Torre said in the letter.
"The combination of infused capital and cash to fund debt will yield an investment by SHC of over $1 billion. This investment will be further augmented by any cash SHC needs to invest to fund losses on operations during the 'turn around' phase of our involvement. (We estimate that the current 'run rate' of these losses is $190 million to $200 million per year.)" de la Torre said in the letter.
JHS and PHT did not immediately respond to requests for comment on the letter.
SHC asked the PHT for an "exclusive" 60-day due diligence period, at the end of which SHC will produce a proposal. If PHT and Miami-Dade County officials approve the proposal, they would be given a 30-day "go shop" period for other interested buyers to review the SHC proposal and make their own bid. If another buyer is selected, SHC would be reimbursed for expenses associated with the due diligence.
"Timing is of the essence," SHC said in its outline of the proposal. "We believe that any delay in this timeline imperils JHS and with it our ability to significantly impact operations. We therefore ask that the PHT provide us any feedback regarding the acceptability of these terms by March 1, 2011."
SHC said it was also willing to fund a "parallel" study by an organization that PHT/JHS chose to "explore the feasibility of JHS remaining an independent organization and still being able to fulfill its mission."
SHC was created by the New York private equity firm Cerberus Capital Management to run the six-hospital Caritas Christi hospital chain in Massachusetts, which was acquired last year in a deal valued at $895 million.
Most U.S. healthcare providers would never photograph patients and post the pictures on the Internet. Doing so, they understand, would violate patient confidentiality, and would merit substantial fines for breaching the federal Health Insurance Portability and Accountability Act.
Yet, some U.S. physicians, nurses, medical students, and other providers who volunteer their medical skills in developing nations have posted pictures of their patients on Facebook and other social media Web sites. That doesn't violate HIPAA because it's beyond U.S. borders, but it is a breach of ethics, University of College of Medicine researchers write in a Journal of Medical Internet Researchstudy. The researchers want providers to respect privacy rights for all patients, regardless of where they're treated and where they live.
"A medical student would not take a picture of a patient in clinic here and post it on Facebook," said Erik Black, an assistant professor of pediatrics with the UF College of Medicine and a lead author of the paper. "But there is a disconnect on these trips. We are not respecting these people as individuals. If we are not going to respect them in the same way we respect patients in the United States, why are we even going?"
UF researchers examined the Facebook profile pages of 1,023 medical students and residents, finding no breaches of patients' privacy in the United States. However, they found 12 photos of patient care in developing countries.
Every year, students from all health fields work in clinics in medically underserved nations, such as the Dominican Republic, Haiti, and Ecuador. It's a chance to get hands-on experience in a patient-care setting and help people who sometimes travel days for care.
HIPAA doesn't apply to patients outside of the United States, says Lindsay Thompson, MD, an assistant professor of pediatrics in the College of Medicine, and a lead author of the report. If a nation has privacy laws in place, doctors must follow them when practicing there.
In addition, Thompson says, doctors are ethically bound to follow the laws of the state or country where they practice. "We in the medical profession have to be held to a different standard. Our actions, however altruistic they are, could have some unintended consequences," Thompson said.
Ruben Ayala, MD, a primary care physician and medical officer with Operation Smile, which provides corrective facial and oral surgery for children in developing nations, said his organization has strict guidelines for using pictures of its patients.
"Anything we put on the Web site or anything we put out in mailings or videos, all of that done only after we double- and triple-check that we have permission from the patients or their parents to do so. Not everybody is eager to tell their story," Ayala says.
"A few years ago we modified our informed consent. In a lot of these countries there isn't a culture of informed consent. These patients, we realized, there is always a chance that because they are poor or don't have access they would think that if they don't say 'yes,' they won't get the surgery. We have to make sure they understand that if they say 'yes' to any pictures that will not increase the changes of their child having surgery, and if they say 'no' that does not decrease the chances of their child having surgery," Ayala says.
Physicians and other medical professionals from the United States who volunteer for Operation Smile must sign a code of conduct that forbids posting pictures of patients. Ayala says that on the rare occasion when they learn that a picture has been posted inappropriate, Operation Smile contacts the healthcare provider and asks them to remove the post. "Most times the reaction will be 'Oh I'm sorry. I didn't realize,'" he says. "I don't know where the disconnect comes from because these are practitioners who would never do this in the United States."
In many cases, medical students and doctors may not realize the differing patient privacy laws in other countries or that that these laws could be even stricter than those in the U.S.
"A lot of people consider this an ethical gray area," said Reed Van Deusen, MD, an assistant professor of internal medicine and pediatrics at the University of Pittsburgh, who was not involved with the study. "It is pretty complicated, but I agree with their basic tenet that trainees, and physicians in general, should not be posting pictures of patients, whether they are in this country or not. I think it is going to take a bit of a culture change to get everyone else on the same page."
Terry Kind, MD, a director of pediatric medical student education at the Children's National Medical Center at George Washington University, in Washington, DC, said medical school faculty must teach students about issues like these, namely by modeling professional behavior themselves.
"(Social media) is here and not going away," Kind said. "There are opportunities for use, but there is risk. The nature of the widespread dissemination is people forget to have that internal check on professionalism."
U.S. patients who agree to be photographed sign consent forms. Black says even getting consent from patients in developing countries poses an ethical challenge, because patients may feel they have to sign the form to receive medical care. Also, because the Internet is borderless, posting pictures to social networking sites could have repercussions for some patients, particularly if the images were taken in countries where being treated by an American doctor is frowned upon.
Even posting photos to a "private" page is not really ensuring patient privacy because, in some cases, the person posting the photo could be sharing it with 1,000 "friends," Black said.
"We are not telling people not to do anything," Black said. "We are telling them to think about it. Use your moral and ethical compass. What if this was your child?"
Maybe hospital executives have too much on their plates already. There may be too many pressing issues to contemplate – such as understanding the impact of the dizzyingly complicated healthcare reforms, installing electronic medical records, or even keeping the doors open and the lights on.
Whatever the reason, the 2011 HealthLeaders Media Industry Survey found that over the past year, recruiting and retaining physicians dropped from the No. 2 “top priority” to No. 7. Did something happen in the last 12 months that relieved the nation’s chronic physician shortage? Did the U.S. demographic get younger, slimmer, more physically fit?
Well, no; the need for physicians is as strong as ever, but the need to focus on recruitment and retention has softened somewhat. The top priorities that ranked above physician recruiting and retention in 2011 are, in order, cost reduction, quality/patient safety, reimbursement, patient experience/patient satisfaction, developing an accountable care organization, and care coordination.
Despite the shifting priorities, hospital leaders do not appear to be in denial about the physician shortage. Only 29% are positive about the supply of primary and specialty care physicians over the next three years, while about 40% see supply as having a negative impact. And yet, 67% of hospital leaders rank their current physician staff as “strong” or “very strong,” which is down from 78% last year. Meanwhile, 9% of leaders describe their physician staff as “weak” or “very weak,” not much better than last year’s 10%.
So leaders need to decide as they walk past every 10th physician, should physician recruitment—with an eye on quality—be a higher priority?
The College of Healthcare Information Management Executives (CHIME) has recommended that the federal government push back the deadline for Stage 2 implementation of meaningful use until the impact of Stage 1 on hospitals can be more accurately evaluated.
"Absent such as assessment, we greatly fear that the (Health Information Technology Policy Committee's) proposals for Stage 2 may be unduly ambitious, even unattainable, for many eligible hospitals and eligible professionals," CHIME President/CEO Richard A. Correll and Lynn Vogel, MD, chair of the CHIME board, said in the Feb. 18 letter to Joshua Seidman at Health and Human Services' Office of the National Coordinator for Health Information Technology.
The CHIME leaders said that seeking public comment about Stage 2 implementation before a proper assessment of Stage 1 "is a big like putting the cart before the horse."
CHIME recommended not moving to Stage 2 until about 30% of eligible hospitals and providers have been able to demonstrate competency with stage 1 meaningful use.
"We believe this approach would strike a reasonable balance between the desire to push EHR adoption and MU as quickly as possible and the recognition that unreasonable expectations could end up discouraging EHR adoption if providers conclude that it will be essentially impossible for them to qualify for incentives," CHIME wrote.
CHIME also suggested that Medicare allow hospitals and providers to "skip a year" if they are not fully prepared to move to the next stage. "CHIME sees no value to imposing some artificial deadline on the movement to stage 2 and urges ONC and CMS to take all the time needed to produce clear and understandable policies. We consider this better than rushing the rulemaking process only to have to repeatedly issue frequently asked questions (and answers) and other policy clarifications and explanations to address provider and EHR vendor confusion and uncertainty," CHIME said in the letter.
