Dear Secretary Sebelius:
The undersigned organizations write to express immediate concerns confronting our respective
members’ ability to comply with the Medicare and Medicaid Electronic Health Record (EHR)
Incentive Program. We recognize the vital role your department has taken in advancing the
adoption of health information technology in the United States and appreciate your willingness
to be flexible in extending the start of Stage 3 to 2017. We fear the success of the program is in
jeopardy, however, if steps are not taken now to address our shared concerns.
Over the next seven months, more than 5,000 hospitals and 550,000 eligible professionals must
adopt the 2014 Edition of Certified Electronic Health Record Technology (CEHRT) and meet a
higher threshold of Meaningful Use criteria. Failure to do so will not only result in a loss of
incentive payments, but also the imposition of significant penalties. With only a fraction of 2011
Edition products currently certified to 2014 Edition standards, it is clear the pace and scope of
change have outstripped the ability of vendors to support providers. This inhibits the ability of
providers to manage the transition to the 2014 Edition CEHRT and Stage 2 in a safe and orderly
manner.
We are concerned this dynamic will cause providers to either abandon the possibility of meeting
Meaningful Use criteria in 2014 or be forced to implement a system much more rapidly than
would otherwise be the case. The first choice limits the success of the program to achieve
widespread adoption of EHR, while the second is highly disruptive to healthcare operations and
could jeopardize patient safety. As you know, our members’ number one priority must be to
provide safe and high quality care to patients.
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