Re: Medicare and Medicaid Programs; Modifications to the Medicare and Medicaid Electronic
Health Record (EHR) Incentive Programs for 2014; and Health Information Technology: Revisions
to the Certified EHR Technology Definition
Dear Administrator Tavenner and Dr. DeSalvo,
On behalf of 4,000 practicing neurosurgeons in the United States, the American Association of
Neurological Surgeons (AANS) and the Congress of Neurological Surgeons (CNS) appreciate the
opportunity to comment on proposed modifications to the Electronic Health Records (EHR) Incentive
Program.
Overall Concerns
The AANS and CNS support the goal of a national health information infrastructure and recognize the
potential value of EHRs to improve the quality of patient care. Nevertheless, there are considerable
barriers to widespread adoption of EHRs, including high cost, lack of functionality (especially for
specialists, who require much more tailored EHR systems), lack of relevant measures in the incentive
program, and interoperability challenges. Physicians, their practices, and their EHR needs are not
homogenous. Many specialists have adopted EHRs into their practice, but still choose not to participate
in the EHR Incentive Program due to a lack of relevant measures. Furthermore, many EHR products do
not work in a way that meets their patient’s needs and many meaningful use measures do not result in
the collection of data that is important to those providing specialty care.
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