June 13, 2017: MGMA IPPS Proposed Rule comment letter

June 13, 2017  

The Honorable Seema Verma
Administrator Centers for Medicare & Medicaid Services
Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201

Re: CMS-1677-P

Fiscal Year (FY) 2018 Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long Term Acute Care Hospital (LTCH) Prospective Payment System Proposed Rule, etc.

Dear Administrator Verma,

The Medical Group Management Association (MGMA) is supportive of physician practice adoption of health information technology (HIT) and the use of HIT to deliver high-quality patient care. MGMA appreciates the opportunity to provide comments on the Fiscal Year (FY) 2018 Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long Term Acute Care Hospital (LTCH) Prospective Payment System Proposed Rule.

MGMA is the premier association for professionals who lead medical practices. Since 1926, through data, advocacy and education, MGMA empowers medical group practices to create meaningful change in healthcare. With a membership of more than 40,000 medical practice administrators, executives, and leaders, MGMA represents 18,000 organizations of all sizes, types, structures, and specialties that deliver almost half of the healthcare in the United States.

The objective of HIT is to improve healthcare quality, control growth in costs, enhance the efficiency of healthcare administration, stimulate innovation and ensure the privacy and security of patient information. The overarching goals of the Centers for Medicare & Medicaid Services (CMS) and the office of the National Coordinator for Health Information Technology (ONC) should be to develop a flexible set of supporting regulations with the goal of improving the nation’s healthcare delivery system while meeting statutory mandates. We assert that in order to fulfill these objectives, the Meaningful Use Incentive Program requirements must be achievable and verifiable without creating an undue burden on eligible professionals (EPs) and their administrative staff.

We have grown increasingly concerned regarding the government overreach with respect to the Meaningful Use Incentive Program. The previous Administration produced a regulatory environment that is clearly contrary to the intent of the originating statute and served to distract clinicians from patient care and stifle vendor innovation. We hope that these comments on the IPPS proposed rule will serve as a guidepost for improving the Meaningful Use Incentive Program, the Merit-Based Incentive Payment System (MIPS), and the advanced Alternative Payment Model (APM) program going forward.

 

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