Skip to Content

Filter by:

Washington Highlights

AAMC Submits Comments on Meaningful Use Stage 3 RFC

January 18, 2013—The AAMC Jan. 14 submitted comments on the Health Information Technology Policy Committee’s (HITPC) Meaningful Use Stage 3 request for comments (RFC). This RFI is the precursor to the third step in the Medicare and Medicaid Electronic Health Record (EHR) incentive program, in which the Centers for Medicare and Medicaid Services (CMS) will publish a proposed rule on Stage 3 requirements.

The AAMC outlined a number of key themes and recommendations for inclusion in the Stage 3 proposed rule, including:

  • The requirement to fully meet all meaningful use measures should be sufficiently flexible;

  • A single set of federal privacy laws should be established for patient consent and disclosure information;

  • The Office of the National Coordinator (ONC) should ensure that measure documentation is accurate and enhances patient care;
  • There should be little or no expansion of the number of measures that rely on actions by others that are wholly outside the control of the physicians and hospitals; 
  • All newly proposed Stage 3 measures should be menu measures and should not be placed directly into the core set;
  • Stage 2 menu measures should not become core measures for Stage 3 until sufficient evidence exists that all types of providers have been able to meet these requirements;
  • For any measures that require attestation, CMS should provide timely and detailed guidance so that physicians and hospitals have sufficient notice about what will be required when such measures are audited;
  • Before any new quality measures are proposed, ONC should allow hospitals and physicians enough time to ensure that their current EHR systems are fully functional and are capturing and accurately generating quality measure data; and
  • Any standards related to privacy and security should be consistent with — and not seek to expand — requirements governed by HIPAA regulations.

 CMS finalized Stage 2 requirements in August 2012, which will take effect in 2014. For additional information on AAMC HIT-related materials, please visit


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

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