SNM Submits Comments to CMS Regarding EHR Stage 2 Proposed Rule

May 8, 2012

SNM Submits Comments to CMS Regarding EHR Stage 2 Proposed Rule

The Centers for Medicare and Medicaid Services (CMS) issued the Electronic Health Record Incentive Program, Stage 2, proposed rule on March 7, 2012.  This proposed rule specifies the Stage 2 criteria that eligible professionals, eligible hospitals, and critical access hospitals (CAHs) must meet in order to qualify for the Medicare and/or Medicaid electronic health record (EHR) incentive payments.  Additionally, it proposes the payment adjustments under Medicare for covered professional services and hospital services provided by eligible professionals, and CAHs failing to demonstrate meaningful use of certified EHR technology and other program participation requirements.

Hospital-based eligible professionals are exempt from individually submitting qualifying data and therefore, SNM focused its recommendation on the CMS proposal to offer a fourth category of exemption to non-hospital based practitioners.  SNM also signed on to the comment letter submitted by the American Medical Association. 

To view both the SNM Comment Letter and the Sign on Letter, please click on the attached documents.

Sign on Comment Letter on Stage 2

SNM Comment Letter on EHR Stage 2 Proposed Rule