HIMSS Public Comment Letter on the Meaningful Use Stage 3 Proposed Rule

In a May 28th letter to Andrew Slavitt, the Acting Administrator of the Centers for Medicare and Medicaid Services (CMS), HIMSS submitted its final comments in response to CMS’s Meaningful Use Stage 3 Notice for Proposed Rule Making (NPRM).

HIMSS appreciated the opportunity to leverage our members’ expertise in commenting on the NPRM, and our dialogue with CMS on the continued advancement and improvement of the Electronic Health Record (EHR) Incentive Program moving toward Meaningful Use Stage 3. 

HIMSS reiterated its commitment to making the EHR Incentive Program less prescriptive and more focused on encouraging and assisting providers to take advantage of the substantial capabilities established in Meaningful Use Stages 1 and 2.  HIMSS also applauded the proposal in the NPRM for a single definition of Meaningful Use starting in calendar year 2018, no matter when a provider began to participate in the EHR Incentive Program.  In addition, HIMSS supported the work being done by CMS to align the EHR Incentive Program with other CMS quality reporting programs that also use certified health IT, which will lessen the reporting burden on providers.  Moreover, HIMSS is committed to ensuring patient safety remains paramount to the development and implementation of health IT systems.