Skip to Content

Filter by:

Washington Highlights

AAMC Comments on Revisions to the Certification Program for Electronic Health Records

May 11, 2012—In a May 7 comment letter , the AAMC responded to the Office of the National Coordinator for Health Information Technology (ONC) regarding a proposed rule on Health Information Technology (HIT) standards, implementation specifications, and certification criteria for Electronic Health Record (EHR) technology. The AAMC’s comments reflect AAMC member input that would lead to EHRs becoming more useable and meaningful for vendors, providers, researchers, and most importantly, for patients.

The AAMC letter focuses on proposals related to clinical quality measures, a single summary care format, problem list coding, patient information reconciliation and incorporation, the ability for EHRs to account for disclosures, and the timing of certification requirements.

The AAMC highlights that for an EHR product to achieve certification, it should be tested and demonstrate its capability to capture correctly and report all clinical quality measures (CQMs) for which the EHR technology developer seeks certification. Additionally, the AAMC asks that ONC and the Centers for Medicare and Medicaid Services (CMS) confer to determine which measures are “EHR-ready” and that proposed CQM measures be reviewed annually by a technical panel during the pre-rulemaking process.

On the topic of accounting for disclosure, the AAMC strongly objects to changing the proposed rule from optional to mandatory or that any other changes should be made to the certification criterion. The AAMC objects to the proposal as being unworkable and extremely burdensome on providers and asked that the access report requirement be withdrawn.

In addition to other comments on problem list coding, disclosure accounting, and a single summary care format, the AAMC urges ONC to publish final certification rules at least one year before vendors are required to be certified. To allow sufficient time for hospitals and EPs to incorporate these changes into their EHRs and to make adjustments to their workflow, the AAMC believes they should be given at least three years from the time the products are certified before they are expected to use them.

The AAMC letter applauds ONC for its effort to propose criteria and standards that reflect the multi-stakeholder consensus that fewer, more complete standards will lead to greater interoperability and effective use of EHRs.


Ethan Kendrick
Senior Program Specialist, Health Care Affairs
Telephone: 202-741-5461


envelope on a green background

Subscribe to Washington Highlights

RSS icon

Subscribe to RSS

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

Past Issues

For More Information

Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806