Thanks Rob and good afternoon everybody. Just to let you
know the Federation is the national representative of investor-owned
hospitals. We represent over a thousand hospitals across the country:
teaching, non-teaching, urban, rural, in-patient rehab, long-term acute
care, psychiatric, cancer. So we kind of run the gamut. We certainly
appreciate CMS and ONC setting up this session today. It's a very
important issue and one I'm glad there was follow-up on. It's really
important that this dialogue continue. We as an organization agree with
most everything we heard today and add our voice to many of the points
that have been made both by our hospital colleagues as well as our
physician and vendor partners and this dialogue does need to continue.
We have obviously many over-lapping themes we've heard today and so in
my brief remarks I'm going to focus on four areas that we wish to
emphasize. There are multiple reasons for higher coding in the
emergency departments now. As I sat here today it really occurred to me
isn\'92t that in part the reason why the Affordable Care Act was passed.
We have many, many uninsured people growing by the day who are not
getting primary care when they need it and end up showing up in
emergency departments when they have a developed medical condition. I
hope that we can sit here in three years and look back and say that the
trend has gone downward because of the Affordable Care Act. I really
think that's one of the things we need to keep as a broader perspective
about this. Clearly my hospital colleagues this morning did a wonderful
job in showing you the data about the higher acuity. But also there's a
baseline of just better documentation will lead to better coding. As we
prepared our statement we talked to many of our members who brought in
their physicians and did talk about how there has just traditionally
been under-coding simply because either one, there's not enough
documentation, but illegible writing of documentation in the record and
for a concern of safety to code to a lower level so as not to be
scrutinized later. So I think more complete documentation leads to
better coding and improved coding is not necessarily up coding per se.
And finally I think that standardization of medical documentation data
sets is not necessarily a bad thing. I was concerned and moved by
hearing the statement this morning about a Medicare carrier who may just
deny a claim simply based on the fact that it looks a lot like a
previous record from a previous provider. I think what we're trying to
do here is develop data sets at the local provider level that are
consistent so that we can then plug into a larger health information
network where there is better population help because we are sharing
information. To the extent that that involves some standardization it
seems like that's a good thing, not a bad thing, and so I would hope
that at the claims level that people aren't necessarily interpreting
that in the wrong way.\ My second point is EHR adoption in hospitals is
really occurring within a culture of compliance. Hospitals have
operated compliance programs for many, many years now. Part of that is
overseeing not only the billing and coding before it goes out the door
through checks and balances but follow-up auditing and monitoring and
obviously responding to medical post-payment reviews by government and
other private payers. This is not an entirely automated prospect for
us. As we talked to our members we clearly heard that the EHR would
help lead to a point, but then there's a manual intervention. And so if
something looks like it's inappropriate from either from a repetitive
standpoint or something else that raises a concern in the documentation
there then can be manual follow-up. So it's not a completely automated
system and it will remain to be seen whether it really ever could be in
a way that would be without checks and balances. I'll make another
comment on that in my next point. Third, as EHR products continue to
mature, more safeguards against improper use of documentation should
really be built in. There are products out there now we heard about the
carry forward of information. As we understand it there are some
products that mark that so it's clear that it's information that's been
carried forward, others do not. It's just an example that as that
field, that market place matures that there will be more safeguards in
place to be able to do this. Hospitals are in a difficult position
because many of us are buying either products off the shelf or designing
products with the vendor that basically we provide care and we\'92re
using the utilization of what we're given. So as those products develop
we'll be better at what we can do and it's important for us to partner
with the vendor community to be able to give the necessary feedback
about what we think would be helpful in those products. And we would
hope that ONC would look at that area for future certification standards
as well. And finally I think policy makers should just strike a proper
balance between the level of scrutiny on individual utilization of EHR
products and put the necessary focus on providing care. I thought both
Dr. Stark and Dr. Mitchell made excellent points today about how onerous
it's become on physicians to really document. I think that the need for
documentation is very important but we certainly should not let it usurp
the patient care. We need to be efficient in the system. We certainly
are looking at a system where we are investor-owned hospitals. I'm not
sure that we've ever seen a strong business case for EHRs but we know
it's the right thing to do for patients and we're doing that. But if
we're going to have too much onerous oversight about how those are used
or what's actually required for that it's going to drive costs, it's
going to deny access because it's just going to mean physicians and
hospitals can treat fewer patients and it's ultimately not going to
drive some of the key policy drivers that both the Affordable Care Act
and CMS have stood for a long time. I again say that it's a pleasure to
be with you today. We look forward to continuing this dialogue with you
and thanks again to ONC and CMS.