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The release of the Notice of Proposed Rulemaking (NPRM) for the Centers for Medicare and Medicaid Services’ (CMS) incentive program for the Meaningful Use1 of electronic health records(EHRs) marks a major, positive step forward in the nation’s efforts to improve health and health care by putting modern information technology (IT) tools at the fingertips of medical professionals and consumers alike.
We applaud the US Department of Health and Human Services (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:
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: