The NCMS is a signatory to a letter that offers comments on the proposed rule for implementing the Medicare and Medicaid electronic health record (EHR) incentive programs.
Addressed to Charlene Frizzera, Acting Administrator, Centers for Medicare and Medicaid Services, and coordinated by the AMA, the multi-page correspondence details a lengthy list of concerns that physician and health care-related organizations have with the proposed rule. Among the many issues discussed are implementation of meaningful use, need for small physician practice representation on the Health IT Policy Committee and reasonable timelines and criteria for Stage 1 implementation, and strong concerns about the use of “numerators and denominators” to determine whether a physician meets the requirements. Read the complete draft letter (35 pages).
