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AAMC Comments on EHR Incentive Program

June 19, 2015—The AAMC June 15 submitted a comment letter on the Centers for Medicare and Medicaid Services (CMS) proposed rule on the Electronic Health Record (EHR) Incentive Program - Modifications to Meaningful Use in 2015 through 2017. The rule proposes to remove several topped-out measures, align provider reporting periods, and reduce the number of meaningful use objectives.

AAMC’s comments focus on the EHR reporting period, attestation time frame, delay in Stage 3 implementation, and clearly defining specific standards and measures relative to physician performance, reporting and patient EHR utilization.

Specific AAMC recommendations in the proposed rule include:

  • Not implementing mandatory calendar year (CY) reporting for hospitals until CY 2017;
  • Implementing a shortened reporting period for 2015, while also allowing providers to choose a calendar quarter reporting period versus a 90-day reporting period;

  • Extending the consolidated attestation period from 60 days to 90-120 days; and
  • Refraining from changes to the meaningful use objectives and measures that make achieving meaningful use Stage 2 more difficult.

The AAMC also reiterates that Stage 3 implementation should be delayed in its entirety and that CMS keep a Stage 1 reporting option for eligible professionals and hospitals. The final rule will be released later this year.


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