AMA Letter to Office of the National Coordinator on Certification Standards for EHR Vendors: March 15, 2010

Dear Dr. Blumenthal:

On behalf of the physician and medical student members of the American Medical Association (AMA), I appreciate the opportunity to provide comments on the Department of Health and Human Services’ (HHS) interim final rule (IFR) on an initial set of standards, implementation specifications, and certification criteria for electronic health records (EHRs). The AMA recognizes that an initial set of EHR standards, implementation specifications, and certification criteria are required to ensure that certified EHR technology is capable of supporting the achievement of meaningful use by physicians and other eligible professionals (EPs), as specified under the Medicare and Medicaid EHR incentive programs, beginning in 2011. Not only must EHR technology be “certified” to meet the meaningful use incentive requirements, but EHRs must also adequately meet a practice’s specific workflow and clinical needs.

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