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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 1000 NORTH OAK AVENUE |
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City | MARSHFIELD |
State | WI |
Zip Code | 54449 |
Country | USA |
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5. Senate ID# 57830-12
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6. House ID# 352550000
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TYPE OF REPORT | 8. Year | 2009 |
Q1 (1/1 - 3/31) | Q2 (4/1 - 6/30) | Q3 (7/1 - 9/30) | Q4 (10/1 - 12/31) |
9. Check if this filing amends a previously filed version of this report
10. Check if this is a Termination Report | Termination Date | |
11. No Lobbying Issue Activity |
INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13 | |||||||||
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12. Lobbying | 13. Organizations | ||||||||
INCOME relating to lobbying activities for this reporting period was: | EXPENSE relating to lobbying activities for this reporting period were: | ||||||||
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Provide a good faith estimate, rounded to the nearest $10,000, of all lobbying related income for the client (including all payments to the registrant by any other entity for lobbying activities on behalf of the client). | 14. REPORTING Check box to indicate expense accounting method. See instructions for description of options. | ||||||||
Method A.
Reporting amounts using LDA definitions only
Method B. Reporting amounts under section 6033(b)(8) of the Internal Revenue Code Method C. Reporting amounts under section 162(e) of the Internal Revenue Code |
Signature | Digitally Signed By: Brent V. Miller, Director of Federal Government Relations |
Date | 01/15/2010 |
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code BUD
16. Specific lobbying issues
Provisions of the FY 2009 Budget and Budget Resolution (S Con Res 70 and HR 1105) and related Labor/HHS appropriations legislation regarding funding for the Centers for Medicare and Medicaid Services (CMS) for implementation of the Medicare program and Medicare Advantage Programs, the provision of Medicare and Medicaid services and benefits to patients, incentives to promote electronic health records for all Americans,
and comparative effectiveness research at the Agency for Health Research and Quality (AHRQ).
Labor HHS Appropriations, Appropriations for Community Health Centers, and Increased Funding for Tele-health Activities. Funding for Dental programs in underserved areas. Future funding for Hospital Emergency Department infrastructure in Flambeau, Wisconsin.
Provisions of the American Recovery and Reinvestment Act (HR 1) including appropriations for:
USDA $1.2 B for essential rural clinics, vehicles equipment, etc; Rural business enterprise grants $150 M; $2.5 B Telemedicine, and distance Learning and Broadband deployment.
Labor Workforce programs $3.95 B; $750 M for Training grants for high growth sectors, Priority given to health care sector; Job Corps $250 M.
HRSA - $500 M for community health centers; $500M for health professions training; and $200 M for primary care and dentistry programs.
NIH research $10 billion expansion $1 B for extramural research facilities; $330 M for instrumentation; $8.2 B/2 yrs for the Office of Director for transfer to Institutes for peer reviewed and competitively ranked research.
Comparative effectiveness research at NIH $400 M, AHRQ $300M, and HHS $400M. The funding in the conference agreement shall be used to conduct or support research to evaluate and compare the clinical outcomes, effectiveness, risk, and benefits of two or more medical treatments and services that address a particular medical condition.
HHS ONCHIT $2 B, $300 M of which is for regional efforts for health information exchange; remaining funds can be used for: development of certified electronic health records software if HHS sees that the private market does not meet certain providers needs; training on best practices to integrate health I.T. systems; infrastructure and tools to provide telemedicine; promotion of technologies and best practices that enhance the protection of health information; promotion of the interoperability of clinical data repositories or registries; and improvement and expansion of the use of health I.T. by public health departments. Much of the funds could be distributed to states as planning and implementation grants.
HHS/CDC $1 B of which $300 M is for immunization; and $650 M for evidence based clinical and community based prevention and wellness strategies.
Transportation Surface transportation $1.5 B; Highway infrastructure $27.5B.
HHS HIT Grants to facilitate the purchase, train personnel in use, and secure electronic exchange of health information; Medicare HIT incentive payments up to $44,000 for physicians who are meaningful users of certified EHR technology to improve quality, and who submit quality information (under PQRI - Rules for 2010 forthcoming in July) - with 10% additional in Health professional shortage areas; $11 million for hospitals; Penalties for those physician and providers who have not implemented EMRs begin in 2015. Medicaid incentive payments for non-hospital based physicians, nurse practitioners, nurse midwives, and physician assistants who are meaningful users, but not claiming Medicare incentives equal to 85% of net allowable technology costs not exceeding $63,750. Rural Health Clinics and FQHCs with at least 30% patient volume attributable to Medicaid will be eligible for payments not exceeding $63,750 for the cost of adoption and use of certified HER
Provisions of the FY 2010 Budget and Budget Resolution (S Con Res 13 and H C Res 85) regarding health care reform, funding for the Centers for Medicare and Medicaid Services (CMS) for implementation of the Medicare program and Medicare Advantage Programs, the provision of Medicare and Medicaid services and benefits to patients, incentives to promote electronic health records for all Americans, value based purchasing and geographic fairness in Medicare reimbursement, and comparative effectiveness research at the Agency for Health Research and Quality (AHRQ).
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Agency for Health Care Policy & Research, Centers For Medicare and Medicaid Services (CMS), Health & Human Services - Dept of (HHS), Health Resources & Services Administration (HRSA), Executive Office of the President (EOP)
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
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Miller |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code MMM
16. Specific lobbying issues
Provisions of the FY 2010 Budget and Budget Resolution (S Con Res 13 and H C Res 85) regarding health care reform, funding for the Centers for Medicare and Medicaid Services (CMS) for implementation of the Medicare program and Medicare Advantage Programs, the provision of Medicare and Medicaid services and benefits to patients, incentives to promote electronic health records for all Americans, value based purchasing and geographic fairness in Medicare reimbursement,
a freeze in Medicare reimbursement updates for physician services, and comparative effectiveness research at the Agency for Health Research and Quality (AHRQ).
The following bullet points summarize the objectives of the Marshfield Clinics Health Policy Agenda:
promoting payment fairness in Medicare physician and practice expense payments;
new formulas for aligning Medicare reimbursement with value;
value-based purchasing of health services including bonus payments for high value Medicare Advantage programs;
bonus payments for efficient providers;
bonus payments for primary care providers;
establishment and funding of comparative effectiveness research;
financing for the adoption and utilization of health information technology;
repeal and reform of the Medicare sustainable growth rate mechanism for updating physician payments;
improved reimbursement for the PGP demonstration;
expansion of the PGP demonstration methodology into a national accountable care organization program to extend the physician group practice demonstration; and
opposition to the establishment of a public option in Health Insurance Exchanges if it were to reimburse providers at Medicare rates.
Value Index
Rewarding Value in the Reimbursement System Congress must introduce a value index into Medicare Parts A and B, to reward physicians and hospitals who provide safe, high quality care with excellent service to Medicare patients at a reasonable cost. The value index can be constructed for many types of payment models, including hospital DRG payments, physician fees, payment updates, and other payment formulas. We recommend that the geographic adjustment of physician work should be eliminated as recommended in legislation introduced by Senator Feingold (S 712) and Senator Grassley (S 318), and replaced with a quality/efficiency based coefficient for physician work as soon as possible. Legislation that we strongly support and would accomplish this objective, has been introduced by Iowa Rep. Bruce Braley and Wisconsin Rep. Ron Kind in the House and by Minnesota Senator Amy Klobuchar and Wisconsin Senators Feingold and Kohl in the Senate. The Medicare Payment Improvement Act (HR 2844, S 1249) seeks to reform the Medicare system to one that rewards the value of care over quantity of procedures, improving quality and lowering the total cost of care over time. The bills outcome-based approach creates the incentive for physicians and hospitals to work together to improve quality and use resources efficiently. These provisions were included in Sections 1159 and 1160 of the House Bill, HR 3962, the Affordable Health Care for America Act, and in section 3007 of the Senate Bill HR 3590, the Patient Protection and Affordable Care Act.
Value Based Purchasing
In the traditional fee-for-service system Medicare currently reimburses for units of service, in a manner that promotes service utilization without regard to quality. This has had the effect of economically stimulating growth in the numbers of supply-sensitive services provided by physicians. According to a recent report by the Congressional Budget Office spending in high-spending regions could be reduced without producing worse outcomes, on average, or reductions in the quality of care. (CBO February 2008) Alternatives:
Medicare must capture the data on performance measures utilizing available claims-based data, and/or data recoverable through enhanced IT functions, and validate performance improvement.
Implement quality/efficiency based payments for physician services as soon as possible.
Implement bundled payments for episodes of care.
Implement FFS reimbursement for the value added through care management and coordination of services.
Improve reimbursement for primary care services.
Improve access to care in rural areas.
The Medicare Advantage program provides a capitated reimbursement to health plans for all Medicare benefits provided to enrolled beneficiaries. Corresponding mechanisms for rewarding value in the Medicare Advantage program should offer incentives for those plans that demonstrate superior patient care performance. Performance bonuses should be provided for plans that:
Achieve predetermined quality performance targets;
Adopt health information technology;
Meet standards for care coordination; and
Provide data on comparative effectiveness.
These provisions were included in Sections 1161 of the House Bill, HR 3962, the Affordable Health Care for America Act, and in section 3201 of the Senate Bill HR 3590, the Patient Protection and Affordable Care Act.
Adequate Funding for CMS
The problems facing the Medicare program stem from the nations earliest attempts to make health care services broadly available nationwide without disturbing the economic incentives that were then in place. The federal government developed formulas to evaluate the cost of providing services in different practice settings and in different geographic locations. Those formulas measure resource inputs that have changed over the +40 year life of the program. To ensure affordable access to Medicare services throughout the country Medicare must take steps to refine its measures of the cost of providing services so that Medicares overwhelming financial dominance does not interfere with affordable access in markets that have changed very much since the program began. Congress must ensure that CMS has adequate funding to provide oversight of its many programs, including its measurement of resource and input costs.
Information Technology
Under current law the capital and operating expenses of installing and maintaining electronic medical records (EMRs) are assumed to be part of the overhead expense of a medical practice. Since no more than 5 10% of the physician population has installed EMRs, CMS now obsolete measurement of physician practice expenses reflect minimal average expense associated with IT. Alternatives:
Congress should provide incentives for EMR adoption, and/or utilization, and
Establish standards to facilitate the sharing and exchange of data.
CMS must update its mechanism for evaluating the cost of medical practice.
On December 30, 2009, the Centers for Medicare & Medicare Services (CMS) and the ONC released two regulations required by the American Recovery and Reinvestment Act that lay the foundation for meaningful use of certified electronic health record (EHR) technology. A proposed rule issued by CMS outlines proposed provisions governing the EHR incentive programs, including defining the central concept of meaningful use of EHR technology. An interim final regulation (IFR) issued by ONC sets initial standards, implementation specifications, and certification criteria for EHR technology. Marshfield Clinic is vendor of a proprietary electronic medical record, and closely follows federal developments of the HHS office of the national coordinator and the it HIT Policy and Standards Committees to assure meaningful use of electronic medical records and efficient standards for certification and interoperability of unrelated systems.
Payment Equity for Physician Work
Before MMA 03, Medicares payments were geographically adjusted based upon erroneous assumptions about the cost of hiring and retaining physicians. Congress established a floor payment mechanism for the physician work component of Medicare payment for 04 06 to assure that physicians in low payment localities were compensated for their work at least at the national average payment amount. The payment floor provision expired in 06, but has been extended in federal legislation every year since then.
Alternatives:
The payment floor should be extended indefinitely;
Geographic adjustment of work should be eliminated entirely; and replaced with a coefficient of quality and efficiency.
Support Senator Feingolds bill, the Rural Medicare Equity Act, S 712. These provisions were included in Sections 1157 and 1158 and 1194 of the House Bill, HR 3962, the Affordable Health Care for America Act, and in section 3102 of the Senate Bill HR 3590, the Patient Protection and Affordable Care Act.
Payment Fairness for Practice Costs
The formulas by which Medicares payments are calculated are widely variable throughout Medicare localities, and are based upon outdated data assumptions regarding the cost and organization of medical practice. Alternatives:
Congress should require CMS to administratively revise its measurement of cost of practice to assure the validity and fairness of payments;
A payment floor could be established for practice expense. These provisions were included in Sections 1157 and 1158 of the House Bill, HR 3962, the Affordable Health Care for America Act, and in section 3102 of the Senate Bill HR 3590, the Patient Protection and Affordable Care Act.
Practice Expense Payment Floor Congress must require the Centers for Medicare & Medicaid Services (CMS) to administratively revise its measurement of the cost of practice to assure the validity and fairness of payment. However, in the interim, a payment floor must be established for practice expense to stem the inequities of the current methodology as proposed by Reps. Braley and Kind in HR 2201, the Medicare Equity and Accessibility Act of 2009. Extreme variation induced by errors in the payment methodology may also be reduced without compromising the relativity of payment by establishing a geographic practice expense index that limits to the difference between relative wages and rents between fee schedule areas and the national average as proposed by Senator Grassley in S 318. These provisions were included in Sections 1157 and 1158 of the House Bill, HR 3962, the Affordable Health Care for America Act, and in section 3102 of the Senate Bill HR 3590, the Patient Protection and Affordable Care Act.
Comparative Effectiveness/Evidence Based Medical Informatics Research
Evidence-based medicine relies upon the judicious use of current best evidence in making decisions about the care of individual patients. Key to effective implementation of value-based purchasing initiatives is the systematic development of data that links the health of populations to the medical services the population receives. The application of health information technology and genomic information in population- and community-based health care delivery systems coupled with the development of wellness programs has the potential to substantially improve health and personalized health care on a national basis. These provisions were included in Sections 1401 of the House Bill, HR 3962, the Affordable Health Care for America Act, and in section 6301 and 6302 of the Senate Bill HR 3590, the Patient Protection and Affordable Care Act.
The Physician Payment Sunshine Act, S. 2029, introduced by Senator Kohl with Senator Grassley in the 110th Congress to create accountability among physicians and the manufacturers of drugs and devices that physicians utilize and prescribe for their patients. This legislation would require manufacturers of pharmaceutical drugs, medical devices, and biologics to disclose the amount of money they give to doctors through payments, gifts, honoraria, travel and other means. These provisions were included in Subtitle D of the House Bill, HR 3962, the Affordable Health Care for America Act, and in 6002 of the Senate Bill HR 3590, the Patient Protection and Affordable Care Act.
The Medicare Rural Health Access Improvement Act, S 2786, introduced by Senator Grassley 110th Congress to mitigate current inequities in Medicare reimbursement, improve access to health services in rural and underserved areas, and will begin to close the gap between Medicare reimbursement and the cost of providing services in predominantly rural areas. The legislation establishes a 1.0 floor for physician work and practice expense adjustments. It also revises the work and practice expense formulas to reduce payment differences and more accurately compensate physicians in rural areas for their true practice costs. The bill also extends the five percent incentive payments for primary care and specialty physicians in scarcity areas.
Marshfield Clinic nominated Dr. Douglas Reding for an open position on the Medicare Payment Advisory Commission, and as a candidate for appointment to the Medicaid and CHIP Payment and Access Commission (MACPAC) in 2010.
Support for Rep. Ron Kinds concept of a not yet introduced MEDICARE EFFICIENCY BILL that would amend the CHAMP Act (H.R. 3162) 304 in whole, by establishing that the 5% bonus payment would be expanded to the top 10% of efficient counties; and a corresponding 5% efficiency penalty for physicians in the bottom 10% of efficient counties. These provisions were included in Section 1123 of the House Bill, HR 3962, the Affordable Health Care for America Act.
Medicare Payment Improvement Act of 2009, HR 2844. To amend title XVIII of the Social Security Act to create a value indexing mechanism for the physician work component of the Medicare physician fee schedule. Introduced by Rep. Ron Kind and Bruce Braley. Goal: To increase quality of health care in America and decrease cost. The Medicare Payment Improvement Act will fundamentally restructure the Medicare payment system by finally providing an incentive for physicians to provide high quality care. The bill eliminates a geographic adjuster (Work Geographic Practice Cost Index) from Medicare, and replaces it with a figure that measures Value. The value figure measures both quality of care and cost of care. Regions that provide high quality care at low cost will see their Medicare reimbursements increase. Regions that provide low quality care at high cost will see their reimbursements decrease. The current structure of Medicare is known as fee-for-service, and incentivizes the number of services performed. The Braley bill shifts this to value-based care, and incentivizes high quality care and low costs. This proposal will transition our current quantity-based system to a quality-based system.
Rep. Braley introduced HR 2201, the Medicare Equity & Accessibility Act. This bill would increase Medicare Part B reimbursement rates in Iowa, by placing a floor on the geographic adjuster (GPCI) that is part of the Part B formula. The bill would have the effect of increasing Part B reimbursements in Iowa and other rural states every time a health care provider sees a patient under Part B.
Rep. Braley and others supporting the Medicare Payment Improvement Act including Reps. Kind, Inslee, and McCollum, who were representing a much broader Quality Coalition, who have been pushing for a value index in the Medicare Part B reimbursement equation to measure quality and efficiency of care. This provision includes the following:
Quality-Based Care--
Instruct IOM to study how to implement a value index in the Medicare payment system. They will consider geographic differences, access to care, measures of quality, and the role of incentives to impact quality and efficient outcomes of care.
After a set two-year timeframe, IOM will make recommendations to the Secretary of HHS on how to specifically change the Medicare payment system to promote high-value care, defined as the efficient delivery of high quality, evidence-based, patient-centered care.
The Secretary will then submit a plan of implementation to the Congress, to implement the recommendations of the IOM.
Congress will have a finite amount of time to pass a joint resolution of disapproval. If Congress fails to act, or if the recommendations are not expressly disapproved by both Chambers, then the recommendations of the IOM will be implemented, thereby reforming the Medicare payment system to incentivize high-value care.
Addressing Geographic Disparity
In addition, the deal resulted in substantive action to address geographic disparity in Medicare payments. IOM will do another study, completed within a year after enactment, to determine whether the data and assumptions used to determine the geographic adjusters (Geographic Practice Cost Indexes and Wage Index) are accurate, or based on flawed data. Many believe the factors that determine these indexes are based on flawed data.
Upon completion of the study (within one year), the Secretary will take immediate action to adjust the GPCIs and Wage Index to ensure they are based on accurate data.
A Medicare Improvement Fund is established, which will consist of $8 billion. From this fund, payments will immediately be made in 2012 and 2013, to ensure the money is there for regions who see an increase in their reimbursement due to the adjusted GPCIs and Wage Index.
In 2012 and 2013, a Hold Harmless will exist to ensure that payments do not decrease in any region as a result of these more accurate measurements. The Hold Harmless expires after 2013, to allow budget neutrality for all appropriate shifts that must be made due to correcting the data in the long-term.
CMS Physician Group Practice Demonstration Marshfield Clinic submitted a proposal for this demonstration and was selected by CMS to participate in the demonstration program, effective April 1, 2005. Marshfield Clinic supported CMS determination to extend this program, beyond its initial 3-year term, and transition these organizations into Accountable care Organizations. Section 1301 of the House bill HR 3962, the Affordable Health Care for America Act, and Section 3022 of the Senate bill HR 3590, the Patient Protections and Affordable Care Act. Marshfield Clinic Also supported efforts to eliminate the 2% threshold for payments and the 5% limitation on payments in the PGP demonstration.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Centers For Medicare and Medicaid Services (CMS), Executive Office of the President (EOP), Health & Human Services - Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Management & Budget (OMB), Medicare Payment Advisory Commission (MedPAC)
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Brent |
Miller |
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Nathan |
Elias |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code HCR
16. Specific lobbying issues
The Physician Payments Sunshine Act (S. 301) introduced by Senator Herb Kohl and Senator Chuck Grassley. This Senate bill would require drug and medical device makers to disclose gifts and payments to doctors, which would be listed online in a publicly accessible database.
Marshfield Clinic has internal policies prohibiting acceptance of gifts of any kind that might be intended to affect the judgment and discretion of it physicians, providers and staff. Section 1301 of the House bill HR 3962, the Affordable Health Care for America Act, and Section 6002 of the Senate bill HR 3590, the Patient Protections and Affordable Care Act
On Dec 19, 2009 Sen. Majority leader Reid released a Managers Amendment S. Amendment 2786 to HR 3590 which proposed reforms of the health care system, including major expansions of public health care programs.
Marshfield Clinic has specific concerns regarding the Expansion of public programs: Temporarily allowing people age 55-64 to buy in to Medicare until an insurance exchange is up and running.
Marshfield Clinic supports Proposals to reform payment to focus on value-based purchasing and also to promote primary care and coordinated delivery. The managers Amendment calls on the Centers for Medicare and Medicaid Services (CMS) to develop a framework to reform and transition the Physician Group Practice Demonstration project into a new program to test cost and quality opportunities of value-based payment to Accountable Care Organization (ACOs).
The Mark also included a Medicare Physician Payment Equity Amendment, "Providing Equitable and Accurate Geographic Adjustments for Medicare Physician Payment." The proposal would direct the Secretary to adjust the practice expense GPCI for 2010 to reflect 3/4 of the difference between the relative costs of employee wages and rents in each of the different fee schedule areas and the national averages (i.e. a blend of 3/4 local and national) instead of the full difference under current law. For 2011, the adjustment would reflect 1/2 of the difference between the relative costs of employee wages and rents in each of the different fee schedule areas and the national averages (i.e. a blend of 1/2 local and 1/2 national). Relief would apply only to areas with a practice expense GPCI less than 1.0. The amendment would hold-harmless any areas negatively impacted by the adjustment. The proposal would direct the Secretary to analyze current methods of establishing practice expense geographic adjustments under the physician fee schedule (PE GPCI) and evaluate data that fairly and reliably establishes distinctions in the costs of operating a medical practice in the different Medicare payment localities. Such analysis shall include an evaluation of: 1) the feasibility of using actual data or reliable survey data developed by recognized medical organizations such as the American Medical Association on the costs of operating a medical practice, including office rents and non-physician staff wages, in the different Medicare payment localities; 2) the office expense portion of the PE GPCI, including the extent to which types of office expenses are determined in local markets versus national markets, and 3) the weights assigned to each of the categories within the practice expense GPCI. Based on the analysis and evaluation, the Secretary shall, no later than January 1, 2012, make appropriate adjustments to the PE GPCI to ensure accurate geographic adjustments across payment areas. Adjustments made in 2012 would be made without regard to the adjustments made in 2010 and 2011. If the Secretary has not completed the required analysis and evaluation and made appropriate adjustments in the Medicare Physician Fee Schedule rule for 2012 (or subsequent year), the 2011 payment rule under paragraph (1) shall remain in effect.
Value Index. Specifically, the amendment requires a separate payment modifier to the physician payment formula, independent of the Geographic Adjustment Factor. This separate payment modifier will, in a budget neutral manner, pay physicians or groups of physicians differentially based upon the relative quality of care they achieve for Medicare beneficiaries relative to cost.
Privacy and Security provisions of HR 1
The American Recovery and Reinvestment Act (HR 1) expands current Federal privacy and security protections for health information. Marshfield clinic has specific concerns about: The bill accomplishes this by:
Providing transparency to patients by allowing them to request an audit trail showing all disclosures of their health information- including treatment, payment and operations- made through an electronic record. Electronic health record (EHR) users or maintainers must provide requesting individuals with an accounting of protected health information disclosures made during the three years prior to the request (but only for as much of that three year period during which the EHR was in use). Marshfield Clinic is concerned about the potential costs and administrative burdens of this provision.
Covered entities must comply with requests to restrict the disclosure of an individuals protected health information if the disclosure is to a health plan for purposes of carrying out payment or health care operations and the information pertains solely to a health care item or service paid for out-of-pocket by the individual. Marshfield Clinic is concerned about the potential costs and administrative burdens of this provision.
In using, disclosing or requesting protected health information, covered entities must limit themselves, to the extent practicable, to limited data sets or the minimum necessary information. Marshfield Clinic is concerned about the potential costs and administrative burdens of this provision.
Marshfield Clinic supports provisions strengthening enforcement of Federal privacy and security laws by increasing penalties for violations and providing greater resources for enforcement and oversight activities.
Meaningful Use of health information technology
On December 30, 2009, the Centers for Medicare & Medicare Services (CMS) and the ONC released two regulations required by the American Recovery and Reinvestment Act that lay the foundation for meaningful use of certified electronic health record (EHR) technology. A proposed rule issued by CMS outlines proposed provisions governing the EHR incentive programs, including defining the central concept of meaningful use of EHR technology. An interim final regulation (IFR) issued by ONC sets initial standards, implementation specifications, and certification criteria for EHR technology. Marshfield Clinic is vendor of a proprietary electronic medical record, and closely follows federal developments of the HHS office of the national coordinator and the it HIT Policy and Standards Committees to assure meaningful use of electronic medical records and efficient standards for certification and interoperability of unrelated systems.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Agency for Health Care Policy & Research, Centers For Medicare and Medicaid Services (CMS), Health & Human Services - Dept of (HHS)
18. Name of each individual who acted as a lobbyist in this issue area
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
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