ANA Comments on Medicare Electronic Health Record Rules
The Centers for Medicare & Medicaid Services (CMS), issued two rules on December 30, 2009, describing the “meaningful use” criteria for the Medicare/Medicaid Electronic Health Record (EHR) Incentive Program, and providing details of how the program will work. On February 12, the Department of Health & Human Services announced nearly $1 billion in grants to fund state health information exchanges, regional extension centers for health information technology (HIT), and job training for HIT careers. A third rule for the EHR program was issued on March 2, regarding certification and testing criteria.
ANA submitted official comments to CMS on March 15. The Alliance for Nursing Informatics (ANI), of which ANA is a member, also commented. ANI is a collaboration of organizations representing 5,000 nurses involved in nursing informatics, which ties nursing care to information technology such as the use of electronic health records.
In ANA comments, we emphasized that HIT programs and systems must embrace all healthcare providers, and called upon CMS, Congress, and the Administration to work to make this happen. Electronic health records cannot become the gold standard of patient record-keeping until HIT programs and policies embrace all healthcare providers. The HIT Incentive Program has closed the door to thousands of dedicated healthcare professionals and the millions of patients they serve, by failing to include many advanced practice registered nurses (APRNs) and other healthcare providers who are not among the few professions listed for Medicare & Medicaid.
No APRNs can qualify for incentives while serving Medicare patients. Nurse practitioners (NPs), certified nurse midwives (CNMs), and physician assistants may qualify as Medicaid “eligible providers,” but nurse anesthetists and clinical nurse specialists cannot. An estimated 14-27 billion dollars is expected to be disbursed in incentives. Virtually all APRNs have some level of prescriptive authority, who are required to check formularies, share prescription information, and ensure accuracy. NPs and CNMs also play an increasingly important role in providing primary care, and serving as medical homes. These limited definitions are preferential, unrealistic, and harm patients.
We also called on CMS to correct the exclusion of providers involved in home care, long-term care, and hospice, from benefitting from the HIT Incentive Program. We also advocated full inclusion of Critical Access Hospitals. These services are essential to the health and well-being of many elderly and disabled Medicare and Medicaid patients.
We also urged CMS to define “meaningful users” of HIT to specifically include RNs and APRNs. RNs are the pivotal professionals providing care coordination and continuity of care – which HIT programs are supposed to enhance. Nurses must also be consulted in evaluating systems for adoption, and those systems should be required to recognize nursing diagnoses and nursing documentation, and accommodate nursing clinical decision support. Furthermore, only RNs are qualified to assess and report on nursing quality measures — an increasingly important component of quality monitoring and improvement — including the National Database of Nursing Quality Indicators™® (NDNQI®) developed by the ANA.
ANA comments also highlighted the need for CMS to implement HIT policies which:
- Acknowledge and assist with the adoption of ICD-10, which recognizes certain services only nurses can provide, regardless of reimbursement. This is a valuable tool in allocating limited health care resources to ensure safe and adequate nurse staffing.
- Streamline burdensome reporting requirements, particularly for the state governments, which already have limited healthcare resources.
- Accommodate care coordination, telehealth, and home care.
- Recognize that implementing HIT/EHR systems in some geographical areas is technically impossible. CMS is proposing to apply penalties, starting in 2015, for providers who fail to fully implement HIT/HER systems.
- Ensure that HIT/EHR systems enable the use of data for Comparative Effectiveness Research, as well as ongoing and future quality initiatives.
The text of the two primary regulations can be found in the January 13, 2010 Federal Register notice, at pages 1843 and 2014, accessible online. For more information on the HIT Incentive Program, several fact sheets and other resources are available on the CMS website.
Eileen Shannon Carlson, RN, JD
Tags: advanced practice registered nurses, APRNs, Centers for Medicare & Medicaid Services, certified nurse midwives, CMS, CNMs, Department of Health & Human Services, Electronic Health Record (EHR), health information technology, HIT, lliance for Nursing Informatics, March 2010, Medicaid, medical homes, Medicare, Medicare Electronic Health Record, NDNQI, NPs, nurse practitioners, nurse staffing, primary care
