Joel Berman-NH

Document ID: CMS-2009-0117-0029
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: January 15 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: 80a7e579
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This is comment on Proposed Rule

Medicare and Medicaid Programs: Electronic Health Record Incentive Program

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As a community hospital employing 150 outpatient PCPs who utilize hospital-based billing, we find the ruling of our ineligibility for the outpatient EHR incentive program non-congruent with the stated objectives of this program. Conceptually, hospital-based billing is a separate and unrelated issue from the capacity to develop and use outpatient EHRs in a meaningful way to improve patient safety and quality. We strongly urge a reconsideration of this issue in order to align the incentives of our institution with the goals of the Office of the National Coordinator.