AOA Comments on Stage Two of Meaningful Use

The AOA recently submitted comments for the preliminary recommendations for Stage 2 of Meaningful Use. Comments received from the preliminary recommendations and feedback from experiences in Stage 1 of Meaningful Use will inform the proposed rule for Stage 2 scheduled to be released later this year.
Comments include:

• Future Stages - Future stages of Meaningful Use must address specific challenges physician practices face in adopting and implementing electronic health records and the impact of these challenges on patient care. The process for physicians to demonstrate Meaningful Use must be done in a way that is applicable to wide variety of physician practice settings.

• Thresholds - In setting thresholds for Stage 2 objectives, feedback needs to be provided on lessons learned, and research completed to ensure proposed thresholds for future stages of Meaningful Use are evidence-based.

• Measures - As future measures are considered, the measures that have electronic specifications should be given first consideration. It is extremely difficult to complete calculations for measures that have not been electronically specified.

•  Mandated Requirements - As new requirements are considered, these requirements should take into consideration other forthcoming mandated requirements such as the conversion to ICD-10. Stage 2 and 3 Meaningful Use criteria must be in alignment with other forthcoming mandated requirements.