Rick Gregory-VA

Document ID: CMS-2009-0117-0026
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: January 14 2010, at 12:00 AM Eastern Standard Time
Date Posted: March 2 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: January 13 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: March 15 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80a7c6b9
View Document:

This is comment on Proposed Rule

Medicare and Medicaid Programs: Electronic Health Record Incentive Program

View Comment

The measurement methodology for the objective: Implement drug-drug, drug-allergy, drug-formulary checks assumes the EHR is complete with this functionality let alone the enable/disable feature. An EHR without this functionality cannot measure compliance with the stated performance. The stated performance is, "...in order to meet this objective, an EP or eligible hospital would be required to enable this functionality." If the functionality does not exist, there with it the ability to enable/disable, the performance cannot be measured. Furthermore it does nothing to insure that the information was available to the EP for consideration. The measurement should be more objective. For example, "At least 10% of all unique patients seen by the EP have drug-drug, drug-allergy, drug-formulary checks performed."