CMS Proposes Changes to the EHR Incentive Program for EPs

In the recently released Proposed Physician Fee Schedule for calendar year (“CY”) 2012 (“Proposed Rule”), the Centers for Medicare & Medicaid Services (“CMS”) proposes changes to the Electronic Health Record (“EHR”) Incentive Program for eligible professionals (“EPs”). Under the Proposed Rule, CMS proposes the continuation of the attestation method of clinical quality measures (“CQM”) reporting for the 2012 payment year. In addition to the current method, CMS also proposes to allow CQM reporting through the Physician Quality Reporting System (“PQRS”)-Medicare EHR Incentive Pilot. Under the pilot, EPs could report the measures through the use of a PQRS “qualified” EHR data submission vendor or the direct transmission of data from an EP’s certified EHR to CMS via a secure portal. In order for an EP to submit CQM data directly, however, the utilized EHR technology would need to be a qualified PQRS EHR product.

For professional assistance navigating the ever-evolving healthcare landscape or more information regarding the Proposed Physician Fee Schedule for 2012, please contact Adrienne Dresevic, Esq. or Carey F. Kalmowitz, Esq. at (248) 996-8510 or (212) 734-0128, or visit the HLP website.