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In a letter to the Centers for Medicare and Medicaid Services, the HIMSS Electronic Health Record Association said a proposed reporting timeline in the 2026 Outpatient Prospective Payment System/Ambulatory Surgical Center Proposed Rule is too aggressive.
Health IT vendors and hospitals need more time to develop and implement the necessary software and staff training, said EHRA leaders.
The organization's additional comments on the 2026 Physician Fee Schedule echoed the theme and urged CMS to prioritize alignment, practical timelines and flexibility across programs like the Quality Payment Program and Promoting Interoperability.
WHY IT MATTERS
Comments in the Sept. 11 letter were in response to the proposed CMS rule related to Medicare Advantage payments for ambulatory care.
The EHR Association said that Jan. 1, 2026, is too soon to be ready to meet the technical obligations that would enable Medicare Advantage providers to report on payer-specific negotiated charges and suggested pushing the suggested compliance deadline in the agency's proposed OPPS/ASC rule out by one year, to Jan. 1, 2027.
Its members need more time to test data extraction and reporting processes, train hospital staff and ensure accuracy across machine-readable files under new processes in EHRs and revenue cycle systems, the association said.
"Ensuring flexibility will be essential to reducing variability and avoiding unnecessary reporting burdens," they explained.
The methodology for calculating the median allowed amount requires that organizations ensure accuracy across machine-readable files, "which already represent a substantial compliance burden" under hospital price transparency rules, EHRA explained.
"Developing and implementing the reporting infrastructure will require significant effort," the association said. "Hospitals and their health IT partners must build new reporting logic within EHR and revenue cycle systems to capture [Medicare Advantage Organizations]-specific negotiated charges at the [Medicare Severity Diagnosis Related Groups (MS-DRG)] level, while also testing data extraction and reporting processes to ensure compliance with CMS’s prescribed methodology."
EHRA also requested clarification on whether hospitals will have flexibility in the data sources and methodologies they can use to calculate the median allowed amount, and suggested allowing the use of Electronic Remittance Advice (ERA)/835 transaction data to reduce burden and variability.
Additionally, the association reiterated requests to CMS to synchronize measures across programs seeking alignment, practical timelines and flexibility, specifically as they relate to the agency's proposed physician fee schedule for next year in a second comment letter, also sent last week.
EHRA asked for flexibility in data sources to ease the reporting burden on healthcare providers.
With specific comments on the Quality Payment Program, Promoting Interoperability and the Ambulatory Specialty Model, the association recommended synchronizing measures and providing multiple reporting options, and cautioned against the Query of Promoting Interoperability Performance Category Measure and other new requirements before adequate standardization and readiness are in place.
THE LARGER TREND
In January, CMS gave a bump to Medicare Advantage plans, while physicians treating Medicare patients faced their fifth consecutive year of payment cuts, according to Dr. Bruce A. Scott, president of the American Medical Association.
"It's unbelievable they're giving insurance companies that had record profits an increase while at the same time cutting payment to physician practices that are struggling to survive," Scott had said in a statement. "This contrast highlights the urgent need for Congress to prioritize linking payment to physician practices to the cost of providing care."
Then, in July, CMS said in an announcement that it is proposing "to reduce payment differentials for physicians across settings of care by leveraging hospital data to calculate more accurate payment rates for certain services and better accounting for increased efficiencies in procedures and tests," when it released the physician payment rule for public comment.
ON THE RECORD
"This timeline does not provide sufficient lead time for the creation, testing and deployment of the new tools and reports needed to capture and submit the median allowed amount," said EHRA officials in a statement about the OPPS/ASC proposed rule.
Andrea Fox is senior editor of Healthcare IT News.
Email: afox@himss.org
Healthcare IT News is a HIMSS Media publication.
