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catalyst corner GAO Sends Message to CMS on EHR Incentive Program A t the ASAP midyear conference upcoming in Philadelphia, I will be providing insights into the Medicare and Medicaid electronic health record (EHR) incentive programs, including where CMS is with regard to the “meaningful use” requirements. Currently, the Stage 2 requirements are open for comment, as I noted in last issue’s column. The initiative is not all smooth sailing. The Government Accountability Office (GAO) issued a report in April reviewing CMS’s activities related to the program (see Web address in box at right). In the report, the GAO concluded that CMS should improve the process it uses to verify eligible healthcare providers qualifying for incentive payments through the program. In the EHR incentive program, providers must meet eligibility requirements that specify the types of providers eligible to participate in the programs, as well as reporting requirements that specify the information providers must report to CMS or the states, including measures that demonstrate meaningful use of an EHR system and measures of clinical quality. These meaningful-use measures have been outlined in three stages. Presently, CMS is promulgating the Stage 2 criteria, as I outlined in the last column. According to the GAO, in compiling the report they examined efforts by CMS and the states to verify whether providers qualify to receive EHR incentive payments and examined information reported to CMS by providers to demonstrate meaningful use in the first year of the Medicare EHR program. GAO reviewed applicable statutes, regulations, and guidance. In addition, they interviewed officials from CMS, four states (Iowa, Kentucky, Pennsylvania, and Texas), members of the AMA, the American Hospital Association, the Health IT Policy Committee, and the Health IT Standards Committee. Additionally, they Marsha K. Millonig, R.Ph., M.B.A. Web Link Links to websites referenced in this article: Government Accountability Office Report on CMS Activity: CMS's Latest Data on EHR Incentive Enrollment: http:// IncentivePrograms/downloads/ Monthly_Payment_Registration_ Report_Updated.pdf FDA Notice: http://www. ?objectId=0900006480fc553c& disposition=attachment&content Type=html analyzed data from CMS and other sources. The report outlines current CMS practices with regard to the EHR incentive program. For Medicare, CMS uses prepayment verification processes for continued on next page May/June 2012 41


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