Daily Dissent, Day 2. Comments to CMS on MACRA proposed rule.


Monday, May 23, 2016

Dear CMS Acting Administrator Mr. Andy Slavitt,

My daily dissent focuses today on C. 2. Meaningful Use Prevention of Information Blocking and Surveillance Demonstrations for MIPS Eligible Clinicians, EPs, Eligible Hospitals, and CAHs, found on pages 33 to 37 of the MACRA proposed rule as published in The Federal Register on May 9, 2016.

The proposed rule for prevention of information blocking and surveillance applies to all MIPS Eligible Clinicians (this definition includes physicians, physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists, and groups that include such clinicians), EPs (this definition-according to the SSA as amended by MACRA last year-includes all EC’s, a certified nurse-midwife, a clinical social worker, a clinical psychologist, a registered dietician or nutritional professional, a physical or occupational therapist or a qualified speech-language pathologist, a qualified audiologist), eligible hospitals, and critical access hospitals: translation of rebranded terminology- this applies…

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