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AAMC Submits Comments on Hospital EHR & IQR Readiness RFI

February 1, 2013—The AAMC Jan. 30 submitted comments  to the Centers for Medicare and Medicaid Services (CMS)’s request for information (RFI) on hospital and vendor readiness for electronic health records hospital inpatient quality data reporting. CMS is seeking feedback on hospitals’ “readiness” to start electronic reporting in the Hospital Inpatient Quality Reporting (IQR) program. The RFI asked questions relating to the alignment of EHR and hospital quality reporting programs, ability of hospitals to meet reporting criteria for Meaningful Use (MU) Stage 1 & 2, and operational challenges for reporting quality data.

The AAMC emphasized the following key points in its comments:


  • Meaningful use (MU) expansion and implementation is moving too rapidly.  While AAMC members are making progress in meeting the electronic reporting requirements for MU Stages 1 and 2, additional time is needed. Hospitals must be able to ensure that current systems are capturing and accurately generating quality measure data prior to the inclusion of new measures in any public reporting program.
  • The AAMC strongly supports the long term goal of electronic reporting for quality metrics, thereby minimizing the burdensome process for data collection and submission.
  • Greater alignment is necessary between clinical quality measure reporting requirements in the EHR incentive program with all other federal hospital quality reporting programs.
  • The best EHR measures should parallel the workflow of health care providers and should be integrated with care delivery. To achieve this goal, CMS should focus on “de novo” EHR-enabled measures that take full advantage of the structure and available clinical data that EHRs offer.
  • There are concerns with the number of e-measure specifications that have not been tested or are not publicly available. E-specified measures should be standardized and rigorously tested and validated before implementation.


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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Telephone: 202-903-0806