The HIMSS Electronic Health Record Association, a trade group of vendors, has joined many other stakeholders in asking the Centers for Medicare and Medicaid Services to significantly streamline meaningful use requirements and change unrealistic compliance timetables.

The association was one of many stakeholders that submitted comments on the proposed rule by the March 15 deadline. "We ask CMS to shift the balance from highly detailed meaningful use criteria/measures and very aggressive timelines to a baseline set of measures, plus the option for providers to defer a small number of criteria in each of the meaningful use categories," according to the association's comment letter.

The sheer number of requirements and the associated complexity could cause a provider "that is really doing everything right to miss the incentives based on small oversights or elements beyond their control," the association contends. "We recommend that CMS consider providing credit for going the right direction and advancing capabilities that are key to improving quality of care."

The bottom line, the association says, is that even organizations very far along in their implementation of EHRs will be extremely challenged to meet the proposed meaningful use requirements. "The focus should be on meeting fewer requirements well instead of spreading implementation across many requirements and making less progress overall."

The association also submitted comments on the interim final rule that establishes an initial set of data standards, implementation specifications and certification criteria for electronic health records. This rule was published in January and is separate from a proposed rule published in March that would establish EHR certification programs.

The organization generally believes the interim final rule moves in the right direction except in three areas:

* The rule adopts the Continuity of Care Document and the Continuity of Care Record as acceptable standards for care summaries. The association recommends using only the CCD, contending the CCR does not support necessary hospital-related information.

* The association is concerned of the lack of specificity for a consistent set of transport services for document exchange.

* The association also is concerned with a lack of support for specific security and privacy standards to achieve effective interoperability.

The comment letter on the interim final rule includes additional recommendations and requests for clarification. Both comment letters are available at

--Joseph Goedert


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