Proposed requirements for Stage 2 of the EHR meaningful use program raise the bar too high “and are not feasible for the majority of hospitals to achieve,” the American Hospital Association contends in a comment letter to the Centers for Medicare and Medicaid Services.

For hospitals and eligible professionals, AHA recommends preserving the current approach of a core set of required objectives and a menu set that gives providers some options, introduce all new objectives through the menu set, move menu items to the core at the same performance threshold set in Stage 1, and remove measures that make the performance of providers contingent on the actions of others.

“Our members are particularly concerned with the proposed objectives to provide patients with the ability to view, download and transmit large volumes of protected health information via the Internet (a ‘patient portal’),” according to the comment letter. “The AHA believes that this objective is not feasible as proposed, raises significant security issues and goes well beyond current technical capacity. We also believe that CMS should not include this objective because the Office for Civil Rights, and not CMS, regulates how health care providers and other covered entities fulfill their obligations under the Health Insurance Portability and Accountability Act, including the obligation to give patients access to their health records.”

The association also recommends that the first year of the Stage 2 electronic health records meaningful use program--and subsequent stages--start with a 90-day reporting period.

“The AHA appreciates the proposed one-year delay in the start of Stage 2, but we caution that the delay may not ensure adequate time to transition from Stage 1 to Stage 2 safely and without undue distortions to the market. We recommend two policies to ease the transition: a 90-day reporting period in the first year of Stage 2 and any subsequent stages, and a length of three years for each stage.”

Further, AHA recommends CMS defer adding new hospital quality measures to the meaningful use program until Stage 3 “so that Stage 2 can be used to make the process viable.” The 68-page comment letter is available at

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