Heart of Health Policy | In May, the ACC submitted comments to the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) on the proposed rule for Stage 3 of the Electronic Health Record (EHR) Incentive Program, also known as Meaningful Use. In its comments, the ACC recognized CMS and ONC’s efforts to ease the constraints and complexities established in Stages 1 and 2 of the program and their attempt to further clarify EHR certification. However, "Overall, the ACC believes the proposed requirements for Stage 3 set the bar for success too high." In separate comments to the Senate Committee on Health, Education, Labor and Pensions, the College called for a delay of Meaningful Use Stage 3, and provided recommendations related to vendor data blocking, effective EHR standards, post-certification surveillance of EHR systems and the reevaluation of the Health Insurance Portability and Accountability Act and security of data. The ACC also submitted comments to CMS on the proposed rule for aligning Stage 2 of the EHR Incentive Program with the proposed Stage 3 rule. The ACC applauded CMS for proposing changes that will benefit providers and patients alike, such as aligning all program participants to reporting on the calendar year, providing for a 90-day reporting period in 2015, and reducing program complexities. "The modifications proposed lay a framework for progress towards a program structure that allows for the broad adoption and improved use of health information technology leading to interoperable health information exchange."

Keywords: Centers for Medicare and Medicaid Services, U.S., Certification, Electronic Health Records, Health Insurance Portability and Accountability Act

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