ACC Urges CMS Not to Put the Cart Before the Horse When it Comes to Next Stage of EHR Incentive Program

The ACC on May 7 submitted formal comments to the Centers for Medicare and Medicaid Services (CMS) on its proposed rule for Stage 2 of the Electronic Health Record (EHR) Incentive Program. As part of the comments, the College urged CMS to release all data pertaining to the first year of the program for a full analysis by interested parties and the public before finalizing Stage 2. In addition, the comments request an extension of the comment deadline to allow the public to incorporate the findings from those analyses into their responses to the proposed rule.

The ACC’s detailed comments look closely at the rule, which contains not only CMS’ vision of the next phase of the EHR Incentive Program, but also a few minor changes to Stage 1. When it comes to Stage 1, the comments strongly urge CMS and the Office of the National Coordinator (ONC) to conduct a survey of program participants to learn more about their experiences than can be gathered from the attestation data. The ACC also recommends that CMS and ONC conduct a survey of eligible professionals who did not participate and a third of those who tried but were unsuccessful to thoroughly understand the implications of their proposals and activities.

In terms of Stage 2, the ACC’s comments in general stress that the proposed requirements “set the bar for success too high.” According to the comment letter: “The Meaningful Use criteria should encourage the appropriate, purposeful and accurate use of EHR solutions, rather than mandate completion of tasks based on a particular timeline. There is too much emphasis on timeline orientation in the proposed criteria, and those timelines are too rigid … When the additional workload is coupled with new and constantly changing requirements, it is clear that the burden imposed by CMS through this proposal for Stage 2 goes above and beyond what providers and vendors are capable of addressing before 2014.”

“CMS and ONC should be commended on their efforts to develop the EHR Incentive Program and the standards, implementation specifications and certification criteria for EHRs. However, the ACC recognizes that these are not easy feats and we are concerned that the sum total of the requirements contained within this proposal seek to change behavior too rapidly without enough appreciation for the potential consequences,” said ACC President William Zoghbi, MD, FACC.  “We will continue to work with both CMS and ONC on this process to help implement the most effective method to enhance widespread adoption of health IT for the betterment of patient care.”

Read more about the specific concerns the College has about the practicability, adaptability, deliverability and ability of physicians to comply with the proposed Stage 2 rule. In addition the College has prepared a special analysis of the Stage 2 requirements. For details  on the EHR Incentive Program, including ACC member resources and information about looming attestation and penalty deadlines, visit the health IT section of In the meantime, the proposed rule does include a delay in implementation of Stage 2 for one year, which will allow for eligible professionals participating in the EHR Incentive program to collect their incentive payments based on Stage 1 requirements for an extra year.

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