HIMSS Submits Comments on CMS Meaningful Use Stage 3 NPRM

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 we look forward to continuing our dialogue with CMS on the continued advancement and improvement of the Electronic Health Record (EHR) Incentive Program moving toward Meaningful Use Stage 3. 

The key takeaways in the comment letter focus on these ideas:

  • HIMSS is strongly committed 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, including interoperability.
  •  HIMSS applauds 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.
  • HIMSS supports 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 burden on providers.
  • As our health IT infrastructure continues to grow, HIMSS is committed to ensuring patient safety remains paramount to the development and implementation of health IT systems. 
  • HIMSS offers its concerns about the timeline for transitioning to Stage 3 in 2017 and 2018.  Since the beginning of the Meaningful Use program, HIMSS has reiterated its position that 18 months is the minimum length of time needed between the final rules on Meaningful Use, certification, and standards, and the start of any stage of Meaningful Use.  This 18-month timeline allows stakeholders to help educate and prepare providers on the upcoming new stage. 

HIMSS’ final comments are available online.