Comments on the Centers for Medicare and Medicaid Services’ Notice of Proposed Rulemaking for the Electronic Health Record Incentive Program

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These comments were jointly developed with a broad array of collaborators, including the Markle Connecting for Health community, the Center for American Progress, and the Engelberg Center for Health Care Reform at Brookings.

The release of the notice of proposed rulemaking, or NPRM, for the Centers for Medicare and Medicaid Services‘ incentive program for the meaningful use of electronic health records marks a major, positive step forward in the nation‘s efforts to improve health and health care by putting modern information technology tools at the fingertips of medical professionals and consumers alike.

We applaud the U.S. Department of Health and Human Services, or HHS, for establishing an important set of priorities and drafting targets that are, in general, both ambitious and staged to enable broad participation. This was a very challenging and novel undertaking, and the result is an important contribution to the potential of information technology to improve the quality and efficiency of health care. In particular, the NPRM:

  • States that the goal of health IT is to improve health quality and efficiency
  • Embraces patient engagement as a key aspect of meaningful use
  • Establishes metrics for health improvement rather than focusing merely on acquiring technology
  • Adopts a phased approach to allow for technology development and testing at initial stages
  • Largely proposes simple and easy-to-use requirements for reporting quality results
  • Makes progress aligning various HHS quality reporting initiatives and eliminating the need for duplicative reporting

While the NPRM takes substantial strides in the right direction, our comments offer specific suggestions for clarifying the regulations and ironing out workable implementation details to achieve the urgent priorities of this effort: improving health and efficient use of health care resources, protecting privacy, and encouraging innovation and broad participation across many health care settings.

In this set of collaborative comments, advanced by a diverse array of health leaders, we offer our comments and recommendations on the NPRM in five distinct categories:

I. Goals and quality measures

II. Eligibility and reporting

III. Patient engagement

IV. Feedback and payment

V. Clarification and technical fixes

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