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Proposed Electronic Health Record Legislation

March 01, 2010

The Centers for Medicare & Medicaid Services (CMS) rule regarding hospital and physician reimbursement for purchase of electronic health record (EHR) technology is open for comment through March 15, 2010.
 
The rule states that the provider or hospital must demonstrate “meaningful use” of a certified EHR to be eligible for reimbursement. As the rule is currently written, claims submission and eligibility transactions could be included within the “meaningful use” requirement.  It is unclear whether those transactions are expected to be part of the EHR application, or if providers could continue to use those functions from their current administrative systems. Most standalone EHRs do not include these capabilities and most standalone administrative systems do not have isolated claims submission or eligibility modules that can be borrowed. The unintended consequence of this legislation, then, could be exorbitant expenses for providers who would not only need to purchase an EHR, but also replace an entire administrative system.
 
We encourage BlueCross BlueShield of South Carolina providers to leave feedback on this legislation before March 15, 2010, and request that administrative transactions such as claims submission and eligibility be removed from “meaningful use” requirements.
 
To comment on this legislation:

  • Go to http://www.regulations.gov.
  • Click on “Submit a Comment.”
  • Under “Select Document Type,” choose “Proposed Rules” and enter keyword “CMS.”
  • Scroll down to the listing for “Medicare and Medicaid Programs: Electronic Health Record Incentive Program.”
  • On the right, choose “Enter a Comment” and follow the instructions.

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