Some infectious disease physicians may find it difficult to quality for new financial incentives that are intended to encourage physicians to adopt electronic health records (EHR) systems. That was the message that IDSA sent to federal officials in a March 15 comment letter on a proposed rule for implementing the new program—which is slated to take effect Jan. 1, 2011.
IDSA told the Centers for Medicare and Medicaid Services (CMS) that the agency’s proposed rule is too administratively burdensome to encourage broad acceptance and participation by ID physicians. Additionally, IDSA said, CMS’s proposed definition of hospital-based “eligible professionals” (EPs) and the agency’s decision not to include a quality measures group specifically for infectious diseases could preclude many ID physicians from participating.
IDSA offered several suggestions to simplify the reporting requirements and expand the number of ID physicians who would be eligible. For example, IDSA noted that ID physicians who provide a substantial amount of inpatient care also play a unique and pivotal role in transitioning hospitalized patients with serious infections to the outpatient setting to receive complex antimicrobial infusion therapies. Unfortunately, hospital EHRs cannot typically be integrated into an office-based practice—meaning that many hospital-based ID physicians still need to purchase their own EHRs and should be eligible for financial incentives to do so.
IDSA also urged CMS to include infectious diseases as a specialty group for the purpose of reporting clinically relevant quality measures through the Physician Quality Reporting Initiative (PQRI). The 2010 PQRI includes eight HIV/AIDS accountability measures that ID physicians who treat this population can use. ID physicians who treat hepatitis C patients may be able to identify with the gastroenterology group. But under CMS’s current proposal, other ID physicians would not qualify.
The HIV Medicine Association (HIVMA) also expressed concerns about the CMS proposal, urging the agency to simplify the criteria and qualifying requirements. The way the program is currently structured, HIVMA said, it would favor larger, better-funded practices and early adopters of electronic records.
The new incentives don’t take effect until 2011, and CMS is expected to issue a final rule later this year that could shed more light on whether more ID and HIV physicians will be eligible.
In the meantime, physicians who believe they will qualify for EHR incentives should take the time to do their homework to ensure they select a system that’s best suited to their practice needs. There is very little financial benefit to implementing a system now, since Medicare/Medicaid incentive payments in 2011 and 2012 will be the same (see CMS chart below).
For IDSA’s March 15 letter to CMS, click here. For HIVMA’s March 11 letter, click here.
For information about selecting an EHR system, see www.idsociety.org/healthit.htm (you must be logged in to access this link).
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