Subject: CMS-1656-P Medicare Program; Revisions to the Hospital Outpatient Prospective
Payment and Ambulatory Surgical Center Payment Systems and Quality
Reporting Programs for CY 2017; Electronic Health Record (EHR) Incentive
Programs
Dear Mr. Slavitt,
On behalf of the American Association of Neurological Surgeons (AANS) and Congress of Neurological
Surgeons (CNS), representing over 4,000 neurosurgeons in the United States, we appreciate the
opportunity to comment on the above-referenced Notice of Proposed Rulemaking (NPRM).
Electronic Health Record (EHR) Incentive Program
Although unrelated to the Hospital Outpatient Prospective Payment (OPPS) and Ambulatory Surgical
Center (ASC) payment systems, CMS uses this rule as an opportunity to propose changes to the
Medicare Electronic Health Record (EHR) Incentive Program.
90-Day EHR Reporting Period in 2016
For 2016, CMS proposes to allow all eligible professionals (EPs) and eligible hospitals, including
returning participants, to use a 90-day reporting period rather than report over the entire year. The
AANS and CNS appreciate this proposal since it would provide EPs with more flexibility to acclimate to
recently modified EHR Incentive Program measures. However, we are concerned that this proposal
would not be finalized until November 2016, when it will be too late for EPs to take advantage of the 90-
day reporting period. Therefore, we urge CMS to implement this policy as soon as possible. If that is not
feasible due to the requirements of rulemaking, CMS adopt a hardship exemption that accommodates
this change should physicians be unable to meet the 90-day reporting requirement as a result of the
delays in finalizing a shorter reporting period.
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Read full letter here
