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AAMC Comments on Meaningful Use Stage 2 Proposed Rule

May 11, 2012—The AAMC submitted a May 7 comment letter to the Centers for Medicare and Medicaid (CMS) on the agency’s proposed rule on Meaningful Use Stage 2. This is the second step in the Medicare and Medicaid Electronic Health Record (EHR) incentive program. The AAMC’s comments focus on the proposed “aggressive” requirements and timelines for achieving the second stage of Meaningful Use.

The AAMC expresses concerns with the proposed expansion of new and untested core measures and urges CMS to provide greater flexibility for eligible professionals (EPs) and hospitals to report this data. Under the rule, hospitals would be required to meet (or qualify for an exclusion for) 17 core objectives and three of five menu objectives. EPs would be required to meet (or qualify for an exclusion for) 16 core objectives and two of four menu objectives

The AAMC also requests that CMS increase the amount of time for new attesters to meet the requirements for Meaningful Use Stage 1. Under the proposed rule, EPs and hospitals that attest after 2011 would have two years, instead of three, to meet these requirements. The AAMC letter notes that EPs and hospitals should have additional time to ensure that the proper infrastructure is in place to capture the necessary data before publicly reporting this information.

The AAMC comments extensively on the expansion of clinical quality measures (CQMs) that have been proposed for both EPs and hospitals. The association expresses its concerns with the inclusion of quality measures that are not market ready and would not lead to better outcomes in patient care. The AAMC letter states that the quality measures proposed for meaningful use should not be incorporated into the pay-for-performance programs without a supplemental process to ensure the validity of the EHR data capture. The AAMC additionally supports group reporting options for CQMs and meaningful use measures

Stage 1 requirements were finalized on July 28, 2010. The Stage 2 final rule is expected to be released in late Summer 2012.


Scott Wetzel, M.P.P.
Lead, Quality Reporting
Telephone: 202-828-0495


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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

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