September 1, 2011 — The HIMSS Electronic Health Record Association (EHR Association), a collaboration of 42 EHR supplier companies, in responding to the Center for Medicare and Medicare Services (CMS) proposed rules for the Medicare Physician Fee Schedule (MPFS) and the Hospital Outpatient Prospective Payment System for 2012, asked CMS Administrator, Donald M. Berwick, MD, to reconsider its proposal to require the submission of patient-level data as it pilots electronic submissions of clinical quality measures (CQMs) based on the burden it would impose on provider organizations and other considerations.
“Our comments on these lengthy proposed rules focus on issues related to electronic health records (EHRs),” said Mark Segal, PhD, EHR Association past vice chair and member of the EHR Association Executive Committee and Vice President, Government and Industry Affairs, GE Healthcare IT. Dr. Segal went on to add, “Although we’re supportive of many of the proposed changes, we have serious concerns about the complexity and overhead of reporting discrete patient-level data for quality measures, rather than summary data, as is the case today. Other aspects of the proposed changes for 2012 make a lot of sense. For example, allowing eligible professionals (EPs) to use either a qualified e-prescribing system or certified EHR technology for reporting helps physicians get value from their investments in health IT.”
The Association also expressed strong support for CMS’ stated intent to align the Medicare Physician Quality Reporting System (PQRS) and EHR incentive program quality measures and reporting approaches, as well as the general intent to pilot electronic reporting of quality measures and the continuation of the current EHR incentive program attestation approach for quality measure reporting.
“In the current environment, providers must understand and comply with several new programs, so it’s important that elements that are proven and operational be maintained in order to minimize uncertainty and maximize the value of prior technology investments,” added Leigh C. Burchell, Vice President of Government Affairs for Allscripts and Chair of the Association’s Public Policy Workgroup. “Therefore, we would like CMS to reconsider its decision not to use the Physician Quality Reporting Initiative (PQRI) XML format to convey aggregate quality measures data from EHRs for electronic reporting as part of the EHR incentive program, and instead to use for the pilot (and likely beyond the pilot) a relatively untested measure electronic submission format that focuses on patient-level data. We also ask CMS to make other changes to their proposed pilots that would encourage wider participation,” Ms. Burchell concluded.
The full text of the Association’s comments on both the physician and hospital proposals at www.himssehra.org.
December 01, 2025 
