May 21, 2012 — The Healthcare Information and Management Systems Society (HIMSS) submitted comments to the Department of Health and Human Services (HHS) in response to the two Notices of Proposed Rulemaking (NPRM) on the Medicare and Medicaid Electronic Health Record (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 [HHS] 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 stage 1 meaningful use 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 United States.
HIMSS strongly suggests the government incorporate a 90- to 180-day reporting period for the first year of Stage 2 in 2014. As part of the preparation for the Stage 2 Final Rule, HIMSS is encouraging HHS to continue reviewing and reassessing the timeline to maximize the amount of time all EPs, EHs, CAHs and vendors have to prepare for Stage 2 meaningful use.
HIMSS also recommends that 2014 (the first year of the new certification criteria and CQMs [clinical quality measures]) be limited to a 90- to 180-day reporting period and 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 the Centers for Medicare & Medicare Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) proposed rules, and provides support—notably, this includes support for the “Base” EHR concept, and for the extension of Stage 1 meaningful use 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; and
- Address questions in the NPRM around accounting of disclosures and data portability.
For more information: www.himss.org
May 21, 2025 
