Daily Dissent, Day 3: Comments to CMS on MACRA proposed rule

krisheldmd

Tuesday, May 24, 2016

Dear CMS Acting Administrator Andy Slavitt,

The MACRA proposed rule requires extensive comment; therefore, I submit my daily dissent part three, focused on Pages 35-37. Section C (2)(b), Support for Health Information Exchange and the Prevention of Information Blocking, amends MACRA and requires that to be a meaningful use EHR user, an EP (Eligible Professional) must demonstrate to your agency that that he or she has not knowingly and willfully taken action (such as to disable functionality) to limit or restrict the compatibility or interoperability of your certified EHR technology. Your rules make corresponding amendments to MACRA applying this to hospitals and critical access hospitals as well. Your rules require us to make a three-part attestation:

  1. That we did not limit compatibility or interoperability of your certified EHR (AKA that we did not block you from getting into our system to steal our data or put…

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