The American Hospital Association has a simple answer for the definition of Stage 3—it’s too soon to define the requirements. “As of September 2012, fewer than one-third of hospitals had met the Stage 1 requirements and received a Medicare incentive payment,” the association notes in a comment letter to the Farzad Mostashari, M.D., national coordinator for health information technology. “In addition, hospitals have not yet had experience with Stage 2, given that the full set of final rules and specifications were just released last fall and no products to support Stage 2 are currently available.”
As the American Medical Association recently recommended, the AHA also calls for a comprehensive external evaluation of the meaningful use program. The hospital association seeks an evaluation “that highlights progress to date, but also seeks to understand why, more than two years into the program, the large majority of hospitals and physicians have yet to attest to meaningful use.” It calls for the HIT Policy Committee to refrain from finalizing Stage 3 recommendations until it has reviewed results of an evaluation and developed an implementation plan for Stage 3 that addresses issues raised in Stage 1.
AHA also calls on the policy committee to focus attention on recommendations related to implementing a nationwide health information technology infrastructure. Three years after passage of the meaningful use legislation and with Stage 2 heavy on data exchange, “we are still without affordable exchange networks and other key components necessary for true interoperability,” the association asserts. “Addressing the current limits to interoperability will bring far greater benefits than rushing into a definition for Stage 3 that is not built on lessons learned from Stage 1, let alone Stage 2.”
The 29-page comment letter, which includes assessments of other aspects of the early scope of Stage 3, is available here.