The American Hospital Association has urged the Centers for Medicare and Medicaid Services not to finalize the proposed Stage 3 electronic health records meaningful use rule. Rather, the association hopes CMS will focus on Stage 2 MU and accelerate the availability of mature standards and the infrastructure needed for health information exchange.

“While the Stage 3 proposals offer promising ideas that could further health information exchange and support greater patient engagement, we do not yet have sufficient experience at Stage 2 to be confident that the proposals for Stage 3 are feasible and appropriate,” states AHA in a May 27 letter to CMS.

Also See: Stage 3 MU Rule Goes Too Far, CHIME Says

According to AHA, 2015 will be the first year at Stage 2 for most hospitals and the vast majority of physicians. As a result, the association argues that CMS must learn from Stage 2, which has been particularly challenging for providers “due to lack of vendor readiness, mandates to use untested standards, insufficient infrastructure to meet requirements to share information and compressed timelines,” before moving to Stage 3.

“The standards and information exchange structures needed to support many of the Stage 3 requirements are not yet mature enough to be included in regulation,” asserts the association. “Furthermore, Stage 3 proposals such as relying on third-party applications to access sensitive patient data in EHRs may be a successful mechanism for the exchange of patient data information, but they raise important questions about patient privacy and information security that must be carefully considered.”

AHA recommends that CMS work with the Office of the National Coordinator for Health IT and the private sector to develop the infrastructure needed to meet the Stage 2 requirements before finalizing Stage 3 requirements.

“We recommend CMS start with standards currently in use in Stage 2, such as the direct protocol and the C-CDA,” according to AHA. “CMS and ONC can then help narrow the disparity between the standard as developed and the expectations for the standard in use. These steps would maximize successful provider use of the standard in their certified EHR. At the same time, new standards to support future goals, such as application program interfaces (APIs), can be developed, piloted and refined before being required for use.”

Though AHA said it supports the concept of using APIs to share data, the organization believes it is also “premature to require their use by providers in meaningful use because of the lack of standards maturity, the security risks they pose and the significant policy questions that must be addressed.”

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