HIMSS EHR Association submits comments on Stage 2 NPRMs

In May 4 responses to notices of proposed rulemaking from both the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health IT (ONC), the HIMSS Electronic Health Records Association logged its comments on the next phase of EHR meaningful use and certification.

The vendor group directed its comments to CMS in relation to objectives and measures for providers' use of certified EHRs, and to ONC in relation to EHR certification criteria and Stage 2 meaningful use standards.

The group also praised CMS’ confirmation of a one-year delay in the start of Stage 2 in order to allow more time for testing and implementation of EHRs updated for Stage 2 – something that had been requested by a wide variety of stakeholder organizations.

"This was truly a collaborative effort that engaged more of our members than any of the previous public comment opportunities," said Leigh Burchell, vice president of government affairs for Allscripts and chair of the association’s Public Policy Leadership Workgroup. “Seven of our eight standing workgroups focused on specific sections of the NPRMs, ultimately collecting feedback from 138 individuals representing 25 member companies. We’re delighted with the level of participation, which represents the majority of operational EHRs in the U.S. and, most importantly, their users, lending credibility and weight to these comments.”

Members noted that comments and suggestions sent to ONC and CMS represent companies ranging from developers of small ambulatory systems to large enterprise systems, software-as-a service models to traditional software, and software module suppliers.

“Through our comments, we try to highlight many of the initiatives from ONC and CMS that we agree with and offer our comments on how to fine-tune other areas for best adoption by our users,” said Carl Dvorak, vice president at Epic and chair of the EHR Association.

“We are honored to carry the message from our customers to ONC and CMS in support of appropriate timelines for not only software development and deployment, but most importantly for safe adoption by clinicians," he added. "In this regard, we strongly support and appreciate CMS’ proposed one-year extension of Stage 1 of meaningful use. We also recommend that CMS and ONC consider the additional ideas shared previously by the EHR Association and again in our comments this week that would build upon the one-year extension and assist in holistically resolving the challenge of appropriately timing Stage 2 for all stakeholders.”

Association members also noted that many elements of both the CMS and ONC proposed rules are aimed at substantially increasing the use and benefit of standards-based interoperability and exchange, which has been one of the EHR Association’s areas of advocacy and support since its inception in 2004.

“Overall, we congratulate ONC and CMS on the tremendous effort that went into the development of the proposed rules, as well as the progress we’ve made as an industry in accelerating the adoption of EHRs and other health IT," said Burchell. "We are ready to work with ONC and CMS to add clarification to the final rules as quickly as possible after they are published to ensure that our companies are ready to support the work our customers will need to do to upgrade their systems and implement many new features prior to the rapidly approaching start of Stage 2.”

Click on the following links to read letters to ONC’s Farzad Mostashari, MD, and CMS Acting Administrator Marilyn Tavenner with their respective comments on the Stage 2 NPRMs.

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