By Mike Cassidy
In two separate letters, one just by the American Hospital Association and one by a consortium of industry groups, AHA, AMA, AMDIS, CHIME, EHRA, FAH and HIMSS, industry has submitted extensive comments to HHS regarding these issues. Comments focus on five areas of opportunity and challenge:
1. Reduce regulatory complexity;
2. Clarify certification and site certification processes;
3. Address meaningful use issues;
4. Clarify and improve the compliance process; and
5. Evaluate/coordinate the overlapping regulatory time line
Although both letters are instructive, the attachments to the AHA letter provide a useful summary of the issues. Attachment A charts the legal barriers to clinical integration, i.e.
- Antitrust
- Stark
- Anti-Kickback
- Civil money penalties
- IRS tax exemption issues
Attachment B indicates the complexity of the overlapping requirements for transition to ICD-10, meaningful use, health reform and HIPAA 5010.
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