Recommendations to CMS on Proposed HIT Incentive Rule: A Rural Perspective
Over the last three months I’ve been blogging about various aspects of the HIT incentive program and related CMS proposed rule. The more I’ve researched, the more convinced I’ve become that the current structure of this program is likely to produce profound negative consequences for the quality and efficiency of healthcare, particularly in rural communities.
The primary reason for this is that designers and supporters of this program have failed to consider whether the totality of the many well-intentioned components of the requirements is achievable in the timeframe established. Numerous constituent groups have piled on, thinking more must be better, while nobody at ONC and CMS has produced an even basic study to estimate how long it will reasonably take for early EHR adoption stage providers to do all of the work safely. Is this really too much to ask?
The issue here is not simply who gets the money. The issue is that decision-makers are incentivizing (and eventually penalizing) providers to quickly adopt technologies that have the potential to do harm if not implemented with reasonable time allowed to perform infrastructure development, workflow assessments, and quality planning. Why are we ignoring decades of lessons learned in EHR implementation case-studies? Why are we asking the taxpayer to spend billions of dollars to buy failed implementations? Why are we not taking the time to succeed?
In the Rural Wisconsin Health Cooperative response to the proposed rule (available at: http://www.rwhc.com/LinkClick.aspx?fileticket=6f_3otUNVxE%3d&tabid=62) we’ve done our best to articulate the problems and propose substantive recommendations for improvement. We encourage readers of our response to post comments, ask questions, and provide additional information.
We also encourage everyone, especially the providers that will be impacted, to submit their own comments to CMS. Comments may include (1) identifying challenges that will be faced by your organization to meet the proposed deadlines, (2) recommending a more reasonable timeline, and (3) articulating potential consequences for your community.
I recognize that rural hospital administrators are busy with hundreds of priorities, but I believe this is as important an issue as any we have seen in a long time. If all of us speak up, there is a real potential we can make a difference. See below for instructions on how to submit comments:
How to Submit Comments to CMS
Comments are due by March 15, 2010
Submitting Electronically:
- Go to http://www.regulations.gov
- Click on “Submit a Comment”
- From the drop down menu under “select document type,” choose “proposed rules.”
- In the “Enter Keyword or ID” field, place the proposed rule’s reference number (CMS-0033-P) and click the “Search” button.
- The search results should bring up only one result, which will say “Medicare and Medicaid Programs: Electronic Health Record Incentive Program”
- On the far right Click on “Submit a Comment”
- On the next page, fill in the requested name/organization information on the left, and either submit the text of your comments in the space given on the right, or click the “Browse” button to attach a file.
- When you are finished, you may preview your comments before submitting, and click on “Submit.”
By Regular Mail
You may mail written comments to the following address ONLY:
- Centers for Medicare & Medicaid Services
- Department of Health and Human Services
- Attention: CMS–0033–P
- P.O. Box 8013, Baltimore
- MD 21244–8013
Please allow sufficient time for mailed comments to be received before the close of the comment period.
By Express or Overnight mail.
You may send written comments to the following address only:
- Centers for Medicare & Medicaid Services
- Department of Health and Human Services
- Attention: CMS–0033–P
- Mail Stop C4–26–05
- 7500 Security Boulevard
- Baltimore, MD 21244–1850
