NAPH Submits Comments on CMS' Meaningful Use Proposed Rule - March 17, 2010

On March 15, NAPH submitted comments to the Centers for Medicare & Medicaid Services (CMS) on its meaningful proposed rule regarding hospital “meaningful use” of Electronic Health Records for the purpose of receiving federal grant funding. In its letter, NAPH urged CMS to:

1. Narrowly interpret the statutory reference to the hospital outpatient setting so that professionals working in non-emergency room outpatient settings can qualify for incentive payments.
2. Use a multi-pronged approach that allows a “hospital” to be defined in ways that acknowledge the varied organizational structures of multi-hospital systems.
3. Specify an alternative source of charity care data for use in calculating hospitals’ incentive payments prior to the availability of revised Internal Revenue Service Worksheet S-10 data.
4. Clarify that the Medicaid incentive payments to hospitals should not be treated as hospital payments for other purposes.
5. Acknowledge the flexibility afforded by the American Recovery and Reinvestment Act and not require Medicaid incentive payments to hospitals to be bound by the Medicare meaningful use phase-in periods.