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Association Urges CMS to Ease Stage 3 Meaningful Use Burden on Providers

America’s Essential Hospitals called on the Centers for Medicare & Medicaid Services (CMS) to delay finalizing the stage 3 proposed rule and to provide much-needed flexibility for providers in the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. The association submitted comments May 29 to CMS on the agency’s proposals for stage 3 of the EHR Incentive Programs (also referred to as the meaningful use programs), which provide incentive payments for providers who adopt and meaningfully use EHRs and assess penalties on those who fail to do so. Stage 3 is scheduled to be the final stage of the meaningful use programs.

In the letter, the association asked CMS to alter the rigid nature of the programs by changing their all-or-nothing structure, allowing for a 90-day reporting period for first-time providers (and for all providers in 2018), and allowing providers three years in a stage before moving on to the next stage. CMS’ proposal requires all providers to be in stage 3 in 2018, regardless of which stage they reported on in 2017. The association also cautioned CMS against using electronic clinical quality measures before they are validated and tested for reliability. Finally, America’s Essential Hospitals urged flexibility on measures dealing with patient engagement and information exchange, which have been historically difficult for hospitals.

The association also joined other national hospital associations in calling for a delay in finalizing the rule until CMS and private stakeholders take important steps toward advancing interoperability. These steps, such as developing new standards for health information exchange, would help prepare providers, vendors, and others for the advanced EHR functions required for stage 3.

Contact Beth Feldpush, DrPH, senior vice president of policy and advocacy, at or 202.585.0111 with questions.


About the Author

Shahid Zaman is a senior policy analyst at America's Essential Hospitals.

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