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AAMC Comments on the EHR Certification Requirements

February 5, 2016—The AAMC Feb. 4 submitted a comment letter on the Centers for Medicare and Medicaid Services’ (CMS) Request for Information (RFI) on Certification Frequency and Requirements for the Reporting of Quality Measures under CMS Programs, including the Inpatient Quality Reporting (IQR) and Physician Quality Reporting System (PQRS) programs.

The AAMC provided broad comments on the RFI, including a request that CMS implement an administrative process to ensure that Electronic Health Records (EHR) vendors expeditiously update their systems to incorporate new data elements, and to ensure that electronic clinical quality measures (e-CQMs) can be exchanged, captured, and transmitted through an EHR.

Noting the time and cost burden to test the collection and submission of new e-CQMs, the association also recommends that CMS only include changes to e-CQMs once per year and allow for flexibility regarding which measures to report.  

In its comments, the AAMC supports certification standards regarding connecting EHRs with registries. While CMS has encouraged providers to use registries as a mechanism for reporting on quality in its programs, many EHR vendors are not transmitting data with registries. Certification standards will help reduce additional burden on providers.


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


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Jason Kleinman
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Telephone: 202-903-0806