Subject: Medicare and Medicaid Programs; Electronic Health Record Incentive
Program—Stage 2; CMS-0044-P; RIN 0938-AQ8
Dear Ms. Tavenner:
On behalf of the American Association of Neurological Surgeons (AANS) and Congress of Neurological
Surgeons (CNS), we appreciate the opportunity to provide comments on the proposed Medicare and
Medicaid Electronic Health Records Stage 2 program. Neurosurgeons are currently working towards
adopting and incorporating electronic health records (EHR) into their practices to improve quality of care,
provider workflow, patient safety and efficiency. However, stringent, overly ambitious incentive program
requirements and the inability of specialists to tailor the program to their practice will hinder widespread
adoption of health information technology by neurosurgeons. Finalizing a program that allows for
flexibility and for physicians to adopt objectives and measures that enhance and meet the needs of their
practice will result in the desired result of extensive use of technology to advance the country’s health
care system.
Neurosurgery understands that the legislation requires Meaningful Use of EHRs, but it provides for broad
discretion in regards to implementation and program requirements. In addition, we recognize that the
widespread and proper use of HIT will help transform health care by facilitating health information
exchange, reducing inefficiencies, and improving quality of care, but to achieve the intended outcome
financial incentives must be associated with realistic and practical measures to support the use of EHRs.
Onerous measures and aggressive thresholds will not.
…
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