The Healthcare Information and Management Systems Society's EHR Association has responded to the Center for Medicare & Medicaid Services proposed rules for the Medicare Physician Fee Schedule and the Hospital Outpatient Prospective Payment System for 2012. The association asked CMS Administrator Donald M. Berwick, MD, to reconsider its proposal to require the submission of patient-level data as it pilots electronic submissions of clinical quality measures based on the burden it would impose on provider organizations and other considerations. "Our comments on these lengthy proposed rules focus on issues related to EHRs," said Mark Segal, EHR Association past vice chair and a member of the EHR Association executive committee and vice president, government and industry affairs at GE Healthcare IT. Segal added, "Although we're supportive of many of the proposed changes, we have serious concerns about the complexity and overhead of reporting discrete patient-level data for quality measures, rather than summary data, as is the case today. Other aspects of the proposed changes for 2012 make a lot of sense.