The HIMSS Electronic Health Records Association is urging federal officials to enable providers still in Stage 1 meaningful use in 2014 to continue to use Stage 1 certified EHR technology rather than switching to the proposed updated 2014 Edition of certified EHRs.

In comments to the Office of the National Coordinator for HIT on the proposed Stage 2 certification process, the association wrote, “As was generally agreed across the industry and by the HIT Policy Committee, a full 18 months is needed between release of the final rules and when providers need to upgrade. As of now, however, it is expected that this will be reduced to approximately 12 months for eligible hospitals and 15 months for eligible professionals.”

The organization also sent a comment letter on proposed Stage 2 requirements to the Centers for Medicare and Medicaid Services, urging a 90- or 180-day reporting period for Stage 2 in 2014.

Further, HIMSS EHRA is concerned that EHR developers and clients will be challenged “by the large number of proposed clinical quality measures and the dearth of available data on their final specifications,” the letter to CMS notes. The group also has concerns that virtually none of the quality measures were initially designed for EHR-based reporting. “The expectation that specifications for the CQM will not be available until summer 2012 creates additional pressure on both vendors and providers.”

Consequently, CMS should finalize far fewer measures for Stage 2 and be highly selective on the measures chosen according to criteria that HIMSS EHRA outlines in its comment letter, the group advises.

The comment letters to ONC and CMS are available at

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