From the August 2011 print issue
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House members have introduced a new bill aimed at fixing what many view as an unjust provision in the government’s program to offer incentives for hospitals that prove meaningful use of electronic health records. Hurray for that. We hope this piece of legislation fares better than a similar bill put forward last year that went nowhere.
The problem is that the rule from the Centers for Medicare & Medicaid Services (CMS) provides payments to hospital systems based on their CMS provider number, and many health systems – which might have five, six, seven or more hospitals at several locations – use one number for all. The health systems that have separate numbers for each of their hospitals are eligible to collect incentives for each. Those that have one number for all campuses would miss out on millions of dollars in incentives aimed at getting those hospitals established in the use of EHRs.
At Sharp Healthcare in San Diego, for example, two of the health system’s four acute care hospitals operate under a single CMS provider number. “So the potential incentive dollars for the two are constrained to the single $2 million base as well as the limit on total discharges,” says CIO William Spooner.
Montefiore Medical Center in the Bronx, N.Y. has three hospitals – each with about 500 beds. As it stands today, however, it would be treated as a single 500-bed hospital, resulting in an estimated $25 million loss in incentive payments.
As Montefiore CEO Stephen Safyer told the American Hospital Association, which has been urging a fix for the situation, the multi-campus provision runs counter to Congress' intention to treat hospitals equitably so they can harness the power of information technology and provide safer, more efficient and effective patient care.
Premier healthcare alliance leaders say that more than 50 member hospital systems, representing more than 100 inpatient facilities, are affected by what Premier calls a "methodological error" in the meaningful use rule.
Tony Trenkle, director of the Office of E-Health Standards and Services at CMS told the House Energy and Commerce Subcommittee on Health at a hearing last year that historically CMS has treated health systems with more than one hospital as an entire institution, and not as separate entities. He said allowing each campus of one hospital to be considered its own hospital for purposes of EHR incentive payments, but not for other purposes, would inappropriately distinguish EHR incentives from other payment and program participation policies.
The Equal Access and Parity for Multi-Campus Hospitals Act (H.R. 2500), put forth last month by Reps. Michael Burgess, MD (R-Texas), Eliot Engel (D-N.Y.), Kevin Brady (R-Texas) and Charlie Rangel (D-N.Y.), and signed on by more than 50 House members from both parties, would correct this “error.”
As Burgess pointed out, if a hospital has multiple campuses, it will be spending money for HIT implementation at each location, and so it should be eligible for incentives for each of them.
"This bill clarifies Congressional intent to provide a common sense, fair approach for multi-campus health systems,” said Rangel as the House members introduced the bill.
It would. And common sense is just what is needed. It makes no sense to treat several hospitals as though they were one on the basis of a provider number. Health systems with several sites will be spending money for health IT implementation at each location, and that’s the way the incentives should be distributed – hospital-by-hospital.
CMS opted for consistency. We say common sense trumps consistency.



