EHR Association Responds To HIT Policy Committee Request For Comments On Stage 3 Meaningful Use

The EHR Association has responded to the HIT Policy Committee’s Request for Comments on Stage 3 meaningful use requirements through their usual workgroup-led collaborative effort, with representatives from 24 of our 41 member companies working on this effort.

The Association’s comments call for a more pragmatic and focused approach to Stage 3 requirements, building on the substantial capabilities established in Stage 1 and especially Stage 2.  As part of this alternate approach, the Association also calls for policymakers to takes into consideration the time and resources required for developers and providers to get all the information needed to effectively develop, test, and adopt new functionality.  As we’ve stated in the past, and aligned with comments from other stakeholder groups, we suggest that ONC and CMS should not start Stage 3 until at least three years after the start of Stage 2.

Specific recommendations include that ONC and CMS invest time and attention to the maturity and alignment of quality measures across regulatory organizations, without adding a significant number of new quality measures, and enhancing infrastructure and standards based on the foundational work begun in Stage 2 to advance interoperability,

The EHR Association also notes that the public and private sectors are shifting to accountable care and value-based payment models, which are creating a business case for providers to adopt and use EHRs and other health IT.  Such market-based demand will drive additional customer-requested functionality and EHR use patterns for those who have already adopted and demonstrated sophisticated use by attesting for Stages 1 and 2.  We believe the needs of such experienced and often sophisticated users will best be met by market innovation, while extensive and detailed standardized requirements dictated by the federal government may actually interfere with the pace and direction of needed innovations.

Go to http://www.himssehra.org/docs/20130115_EHRARespondstoMU3RFC.pdf for the full response.