Medicare and Medicaid Programs: Electronic Health Record Incentive Program-Stage 2

The comment period for “Electronic Health Record Incentive Program-Stage 2” closes Monday.

If you have not yet read CMS-2012-0022-0001, now is  the time.

Civerex displays an active interest in evolving EHR technology and I am reproducing below a copy of our comment #81005bf1  to where we predict the outcome of a forced move away from patient centric to statistical reporting of abstract aggregate measures.

Here below is an extraction of the text of our commentary:

We did a search on “performance” across the Stage 2 NPRM and our comment is that whereas FFS allowed a focus on patient care under the false belief that “more is better”, we predict that any shift to Performance Based Reimbursement is going to abstract this focus to aggregate measures which will not be perceived as “hands on” controllable. 

 Civerex has developed an “earned value” model (on spreadsheet) that allows healthcare providers to track progress toward meeting individual patient objectives, thereby providing a foundation for aggregate measures. 

 The use of a model of this type would allow healthcare professionals to feel that they have control over the measures they will be required to report on (i.e. managing individual patients efficiently will lead naturally to better aggregate outcomes).

 We are willing to contribute this algorithm for general use so long as there is a credit line showing Civerex as the developers of the algorithm. 

 See a writeup on “Adaptive Case Management Earned Value Matrix  Model” at

We are hoping they will take us up on our offer.


Management consultant and process control engineer (MSc EE) with a focus on bridging the gap between operations and strategy in the areas of critical infrastructure protection, major crimes case management, healthcare services delivery, and b2b/b2c/b2d transactions. (C) 2010-2019 Karl Walter Keirstead, P. Eng. All rights reserved. The opinions expressed here are those of the author, and are not connected with Jay-Kell Technologies Inc, Civerex Systems Inc. (Canada), Civerex Systems Inc. (USA) or CvX Productions.
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1 Response to Medicare and Medicaid Programs: Electronic Health Record Incentive Program-Stage 2

  1. Here it is finally . . . (all 2,000 pages)

    Centers for Medicare & Medicaid Services
    42 CFR Parts 412, 413, and 495
    RIN 0938-AQ84
    Medicare and Medicaid Programs; Electronic Health Record Incentive Program–Stage 2
    AGENCY: Centers for Medicare & Medicaid Services (CMS), HHS.
    ACTION: Final rule.
    SUMMARY: This final rule specifies the Stage 2 criteria that eligible professionals (EPs),
    eligible hospitals, and critical access hospitals (CAHs) must meet in order to qualify for
    Medicare and/or Medicaid electronic health record (EHR) incentive payments. In addition, it
    specifies payment adjustments under Medicare for covered professional services and hospital
    services provided by EPs, eligible hospitals, and CAHs failing to demonstrate meaningful use of
    certified EHR technology (CEHRT) and other program participation requirements. This final
    rule revises certain Stage 1 criteria, as finalized in the July 28, 2010 final rule, as well as criteria
    that apply regardless of Stage.


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