HIMSS Submits Comments on Meaningful Use Stage 2 and Standards & Certification Criteria NPRMs

Washington, DC (May 7, 2012) – HIMSS submitted comments to the Department of Health and Human Services in response to the two Notices of Proposed Rulemaking on the Medicare and Medicaid EHR Incentive Programs:  Medicare and Medicaid Programs; Electronic Health Record Incentive Program–Stage 2; and Health Information Technology: Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology, 2014 Edition; Revisions to the Permanent Certification Program for Health Information Technology.

“Since the inception of the HITECH provisions of the American Recovery and Reinvestment Act of 2009 (ARRA), HIMSS has supported the concept of graduated complexity of Meaningful Use that recognizes the varying degrees of maturity of adoption and implementation of health IT that serve as the foundation for healthcare transformation,” said Carla Smith, HIMSS Executive Vice President.  “We appreciate the incredible commitment the Department has placed on engaging in a public dialogue and agree that the Meaningful Use program encourages standards-based collection, analysis, and exchange of health data in a safe and secure environment that can help providers, hospitals, and consumers improve care delivery for all Americans.”

Over the first year of the Meaningful Use Program, HIMSS has observed an increasing amount of resources being utilized to prepare Eligible Professionals (EPs), Eligible Hospitals (EHs), and Critical Access Hospitals (CAHs) for attestation.  As part of its HIMSS Analytics data collection on Meaningful Use activity, HIMSS has seen a 12 percent increase in hospital preparedness for Meaningful Use Stage 1 requirements.  The increase appears to be an affirmation of the impact of the Meaningful Use program, and organizations’ collective willingness to engage in the program as a foundation for improving the quality and cost effectiveness of care delivery in the U.S.

The HIMSS response to the Meaningful Use Stage 2 proposed rule provides support and constructive observations on the Objectives and Measures outlined by the government. To that end, HIMSS strongly suggests that the government incorporate a 90- to 180-day reporting period for Year 1 of Stage 2 in 2014.  As part of the preparation for the Stage 2 Final Rule, HIMSS is encouraging the Department to continue reviewing and reassessing the timeline to maximize the amount of time all EPs, EHs, CAHs, and vendors have to prepare for Meaningful Use Stage 2.

HIMSS also recommends that 2014 (the first year of the new certification criteria and CQMs) be limited to a 90- to 180-day reporting period and also recommends that the Department reconsider the proposal that providers who are in Stage 1 will be required to meet all of the criteria changes to Stage 1 by FY/CY 2014.  HIMSS also recognizes the areas in which its members agree with CMS and ONC proposed rules and provides support—notably, this includes support for the “Base” EHR concept, and for the extension of Meaningful Use Stage 1 for 2011 attesters.

The HIMSS comments also:
• Encourage alignment between federal and state quality reporting requirements.
• Emphasize that Quality Measures should be utilized only if the standard and specifications supporting the quality measure have been tested and verified.
• Encourage the utilization of mobile technologies to support patient engagement.
• Include several requests for additional clarity or definition.
• Address questions in the NPRM around accounting of disclosures and data portability.

For more information visit:
HIMSS Response to Meaningful Use Stage 2 NPRM
HIMSS Response to Standards, Implementation Specifications and Certification Criteria NPRM HIMSS Response to Proposed Certification Criteria Public Comment Template


HIMSS is a cause-based, not-for-profit organization exclusively focused on providing global leadership for the optimal use of information technology (IT) and management systems for the betterment of healthcare. Founded 51 years ago, HIMSS and its related organizations are headquartered in Chicago with additional offices in the United States, Europe and Asia. HIMSS represents more than 44,000 individual members, of which more than two thirds work in healthcare provider, governmental and not-for-profit organizations. HIMSS also includes over 570 corporate members and more than 170 not-for-profit organizations that share our mission of transforming healthcare through the effective use of information technology and management systems. HIMSS frames and leads healthcare practices and public policy through its content expertise, professional development, research initiatives, and media vehicles designed to promote information and management systems’ contributions to improving the quality, safety, access, and cost-effectiveness of patient care. To learn more about HIMSS and to find out how to join us and our members in advancing our cause, please visit our website at www.himss.org.