Payment Matters: HIT Policy Committee Releases Proposed Stage 2 (and Stage 3) Meaningful Use Requirements; Requests Public Comment

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Health care providers who have begun preparations for meaningful use attestations (and are planning to receive the associated incentive payments) should take note that the Stage 2 criteria are currently under development. Providers interested in participating in the standard setting process should review the proposed Stage 2 recommendations [PDF] recently released by the Health Information Technology Policy Committee (HITPC) and comment before the February 25, 2011 close to the comment period. Comments may be submitted electronically (through www.regulations.gov) or via mail or hand delivery to the Office of the National Coordinator for Health Information Technology's (ONC) District of Columbia offices.

The HITPC is the federal advisory committee tasked with advising the Department of Health and Human Services (HHS) with regard to Health Information Technology (HIT) issues, including, especially, what demonstrated HIT capabilities should be required of providers seeking incentive payments for the meaningful use (MU) of electronic health record (EHR) technology. The HITPC does not issue regulations, as it is not a government agency. Rather, it makes recommendations to HHS with regard to the standards that it believes should be incorporated when that agency issues binding regulations. Stage 1 MU criteria have been established by final agency rule. The HITPC recently publicly posted a summary of the MU criteria it proposed recommending to HHS for Stage 2 and, to some extent, Stage 3. Interested parties are encouraged to submit comments to the HITPC regarding the Stage 2 criteria proposed. Interested parties are also encouraged to submit comments in response to a list of questions posed by the HITPC and reproduced below. The HITPC expects to issue its formal and final Stage 2 recommendations in the summer of 2011.

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