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    June 21, 2018

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

    RIN 0938–AT27  

    Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Proposed Policy Changes and Fiscal Year 2019 Rates; Proposed Quality Reporting Requirements for Specific Providers; Proposed Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs (Promoting Interoperability Programs) Requirements for Eligible Hospitals, Critical Access Hospitals, and Eligible Professionals; Medicare Cost Reporting Requirements; and Physician Certification and Recertification of Claims 

    Dear Administrator Verma, 

    The Medical Group Management Association (MGMA) appreciates the opportunity to provide comments on the Fiscal Year (FY) 2019 Medicare Hospital Inpatient Prospective Payment System (IPPS) proposed rule. Our comments will focus on the health information technology (HIT) proposals in the IPPS proposed rule.  MGMA is supportive of physician practice adoption of HIT and the use of HIT to deliver high-quality patient care. 

    Since 1926, MGMA has been the premier association for professionals who lead medical practices. With a membership of more than 40,000 medical practice administrators, executives, and leaders, MGMA represents more than 12,500 organizations of all sizes, types, structures, and specialties that deliver almost half of the healthcare in the United States. 

    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 (renamed the “Promoting Interoperability” program) requirements must be achievable and verifiable without creating an undue burden on providers.  
     We have grown increasingly concerned regarding the government overreach with respect to EHR incentive programs. The previous Administration produced a regulatory environment that was clearly contrary to the intent of the originating statute and served to distract clinicians from patient care and stifle vendor innovation. We hope these comments on the IPPS proposed rule will serve as a guidepost for improving all EHR incentive and quality reporting programs. 

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