The American Medical Association (AMA) submitted formal comments to the Office of the National Coordinator for Health Information Technology (ONC) on the Health IT Policy Committee’s proposal for Stage 3 of the Medicare/Medicaid meaningful use electronic health record (EHR) program requirements.
“The AMA shares the administration’s goal of widespread EHR adoption and use, but we again stress our continuing concern that the meaningful use program is moving forward without a comprehensive evaluation of previous stages to resolve existing problems,” said AMA Board Chair Steven J. Stack, M.D. “A full evaluation of past stages and more flexible program requirements will help physicians in different specialties and practice arrangements successfully adopt and use EHRs.”
The AMA’s comment letter outlined the following top five concerns and recommendations to improve the meaningful use program:
· An evaluation process is lacking. An external, independent evaluation is necessary to improve and inform the future of the program.
· 100 percent pass rate is not the right approach. The pass rate should be reasonable and achievable. Failing to meet just one measure by one percent would make a physician ineligible for incentives and subject to financial penalties.
· One size does not fit all. Program requirements should be more flexible and better structured to accommodate various practice patterns and specialties.
· Usability of certified EHRs should be addressed. The EHR certification process should address physician usability concerns.
· Health IT infrastructure barriers should be resolved. The health IT infrastructure does not enable physicians to readily electronically share patient data with other health care providers; infrastructure improvement to allow an efficient and secure electronic information exchange must be a priority.
For more information: http://www.ama-assn.org/resources/doc/washington/stage-3-meaningful-use-electronic-health-records-comment-letter-14jan2013.pdf
October 25, 2026 
