HIMSS supports the work by CMS in the Physician Fee Schedule Proposed Rule to better align incentives and provide clinicians with a smoother transition to the new Merit-based Incentive Payment System under the Quality Payment Program. We also applaud the proposal to add several codes for telehealth and welcome the opportunity to inform CMS on additional ways to include these services. We believe telehealth can expand access to higher quality care for underserved communities, address provider shortages, facilitate proactive disease prevention, and improve patient and provider satisfaction.
Where our concern lies is that CMS did not use the Outpatient Prospective Payment System Proposed Rule to modify the requirement for the use of 2015 Edition Certified Electronic Health Record Technology (CEHRT) in hospitals starting January 1, 2018. Our concerns with the truncated timeline for providers to be fully up-and-running with new 2015 Edition CEHRT were addressed in our April 2017 letter to Secretary Price. We will continue to provide recommendations to CMS on a timeline that advances clinical outcomes and patient safety.