Electronic Health Record Incentive Program – Stage 2 Notice of Proposed Rulemaking

The undersigned organizations and members of the Health IT Now Coalition are pleased to respond to the Medicare and Medicaid Programs; Electronic Health Record Incentive Program – Stage 2 Notice of Proposed Rulemaking published in the Federal Register on March 7, 2012. Health IT Now (HITN, www.healthitnow.org) is a diverse coalition of 65 organizations, including health care providers, patient advocates, consumers, employers and payers, who support the adoption of health IT to lower costs while improving quality, safety and clinical outcomes. Other organizations have joined our comment letter to highlight the importance of this issue.

We believe the NPRM is a solid first step in promoting information exchange and care coordination. We call on CMS to strengthen the NPRM to facilitate robust interoperability and information exchange. Specifically, we recommend:

1. Ending information exchange blocking;

2. Adopting more robust interoperability standards;

3. Promoting greater patient engagement; and,

4. Coordinating quality measures across Medicare and Medicaid.