CMA submits comments on Meaningful Use Stage 3 to CMS

June 02, 2015

On May 29, the California Medical Association (CMA) submitted comments to the Centers for Medicare and Medicaid Services (CMS) and the National Coordinator for Health Information Technology on the Meaningful Use Stage 3 notice of proposed rulemaking.


Under the federal electronic health records (EHR) incentive programs, qualifying Medicare and Medi-Cal providers are eligible to receive incentive payments for adopting and demonstrating “meaningful use” of certified health information technology (HIT). The proposed rule, published in the Federal Register on March 30, specifies the final stage of meaningful use criteria that eligible professionals, hospitals and critical access hospitals must meet in order to qualify for the Medicare and Medicaid EHR incentive payments and avoid payment adjustments under Medicare.



In its letter, CMA supported the detailed comments submitted by the American Medical Association (AMA) and offered further comments that are of particular concern to California physicians. Specifically, CMA urged CMS to hold off on finalizing Stage 3 Meaningful Use criteria until CMS implements stronger interoperability directives on EHR vendors, including certifying only those EHRs with the ability to satisfy all meaningful use requirements and prohibiting vendors from charging additional fees and costs for necessary upgrades and interfaces to achieve meaningful use.



In addition, CMA argued that proposed measures relating to coordination of care through electronic patient interactions set an exceedingly high bar for physicians in light of the technological limitations and administrative burdens facing many physician practices. Finally, CMA objected to the proposed elimination of the 90-day reporting period for providers demonstrating meaningful use for the first time and recommended a reporting period that is less than a full calendar year for all participants in the EHR incentive programs.



For more information on AMA’s comments on the Meaningful Use Stage 3 proposed regulations, click here.



For more information and resources, including CMA On-Call documents #4302 “Meaningful Use of EHRs: Stage 1,” and #4305, “Meaningful Use of EHRs: Stage 2,” as well as general information on the EHR Federal Incentive Program and Meaningful Use, visit CMA’s Digital Health page. These documents, as well as the rest of CMA’s online health law library, is available free to members in CMA’s online resource library. Nonmembers can purchase documents for $2 per page.






Contact: Lishaun Francis, (916) 551-2554 or lfrancis@cmadocs.org.



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