The American Hospital Association in a recent comment letter to the HIT Policy Committee advocates starting Stage 2 of the electronic health records meaningful use program in 2014, and only when at least 75 percent of eligible hospitals and eligible professionals have reached Stage 1.

The AHA sent the letter two days before the policy committee took a compromise approach, recommending to federal officials that Stage 2 be delayed to 2014 but only for providers that achieve Stage 1 meaningful use in 2011. But the AHA's arguments for a more comprehensive delay in Stage 2 could be influential as Department of Health and Human Services officials make final decisions on provisions in a proposed rule for Stage 2 expected late this year.

"Meaningful use is not the only federal initiative that requires changes to hospitals' I.T. systems," the association argues in its comment letter. "The scope of change currently underway is creating a 'perfect storm' of overlapping requirements that threatens to overwhelm providers."

That storm includes implementing HIPAA 5010 transaction sets, ICD-10, myriad reporting requirements and information transfers for the current quality reporting program under Medicare, numerous initiatives under the Affordable Care Act and participation in state-level health information exchanges, the association notes. Further, hospitals are experiencing increased prices for I.T. systems, delays in vendor schedules, and limited ability to attract and retain clinical I.T. expertise.

"In addition, only 16 states have begun their Medicaid EHR incentive programs, which are meant to serve as a source of capital financing to support adoption, implementation and upgrading of systems in the first year," according to the AHA comment letter.

Among other topics in the letter, AHA argues against a new proposed Stage 2 criteria on the table that would require hospital labs to send structured electronic results to outpatient providers for at least 40 percent of labs sent electronically. "The goal of this objective, to accelerate the electronic standard of laboratory data, is laudable," according to the association. "However, using meaningful use as a 'back door method' of regulating hospital reference laboratories is both inappropriate and beyond the statutory scope of the EHR incentive program."

The AHA's full comment letter on early proposals for Stage 2 meaningful use is available at


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