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Meaningful Use Stage 2 Comment Period Closes Next Week

May 4, 2012
by Gabriel Perna
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Monday, May 7 will close the comment period for the notices of proposed rule-making (NPRMs) for Stage 2 of meaningful use and updated certification criteria. ONC's rule complements the newly released Centers for Medicare & Medicaid Services (CMS) proposed rule for Stage 2 of the EHR Incentive Programs, clarifying the specifications necessary to meet the criteria for these programs.

Comments can be submitted electronically through, which ONC says is the preferred method. Groups can also comment through regular mail, express mail, or via a hand-delivered courier. Faxes are not accepted.

In an attempt to the public comment experience, ONC and CMS have made a copy of the rule available in Microsoft Word to make it easier those who comment to access and copy portions of their proposed rule for use in their individual comments.  The proposed rule can be viewed here:

Already, several groups have made their comments publicly known. The College of Healthcare Information Management Executives (CHIME)said that healthcare organizations need more time for Stage 2. Premier urged CMS to act quick on a final rule, or delay the deadline altogether.  The American Hospital Association (AHA) said that the requirements for Stage 2 from the CMS were too much.

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For Stage 2 the Vendor's products need to show in an actual practice setting that they can meet all the measures and report on them properly. For Stage 1 the vendors were certified, but some of the MU features did not work properly which resulted in the practices having to do a great deal of trouble shooting for the vendors.

If your product doesn't work in the real environment, it should not be certified.

As well, how about a cap on what a vendor can charge for Stage 2 upgrades. With the constant increase in fees from the vendors the practices are having a difficult time paying for these MU upgrades.


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