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HIMSS Electronic Health Record Association Responds to Proposed Meaningful Use and Certification Rules
Date:3/15/2010

In preparing this collaborative response, the Association relied on its workgroup structure, which ensures that representation from both larger, enterprise-focused companies and ambulatory-only EHR suppliers is balanced.  Sixty-three individuals from 28 member companies worked intensively from the time the IFR and NPRM were made public in late December 2009 through early March to develop and refine comments on behalf of the EHR Association.  

Mark Segal, Ph.D., of GE Healthcare and Vice-Chair of the Association noted some of the important points the group made in its letters to ONC and CMS.  "CMS and ONC should reconsider their proposals in the context of Congress' intent for incentives that truly encourage adoption and use of interoperable EHRs.  The sheer number of requirements, and their complexity, could cause a provider that is doing everything right to miss the incentives based on small oversights or elements beyond their control."  

Segal noted the group's general concern regarding quality measure data collection. "The initial meaningful use and quality measures must be more pragmatic, as many providers will be using EHRs extensively for the first time and may not be ready to collect and report on the number of complex indicators called for in the NPRM.  And both EHR suppliers and healthcare providers need more lead time for
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