Multisociety Comment Letter to CMS Regarding Meaningful Use: March 15, 2010
Dear Acting Administrator Frizzera:
We, the undersigned organizations, are pleased to provide comments on the proposed rule for implementing the Medicare and Medicaid electronic health record (EHR) incentive programs. We appreciate the Centers for Medicare & Medicaid Service’s (CMS) efforts to promptly issue a proposal for EHR “meaningful use” objectives and measures that must be met by eligible physicians to ensure receipt of the financial incentives specified in the “American Recovery and Reinvestment Act of 2009” (ARRA), which became law on February 17, 2009. Physicians are deeply supportive of and committed to incorporating well-developed EHRs into their practices to improve quality of care delivery, enhance patient safety, as well as support practice efficiencies. To facilitate this transition, we want to ensure that there is widespread adoption and meaningful use of EHRs by physicians. We do, however, feel strongly that the Stage 1 criteria proposed by CMS for achieving meaningful use of EHRs is too aggressive and if adopted, will deter many physicians from participating in the Medicare and Medicaid incentive programs. This runs counter to the intent of ARRA, which clearly indicated that demonstrating meaningful use should progress over time.
