Public Comment Period Ends

The public comment period for both the CMS NPRM and the ONC IRF ended on March 15th. The ONC and CMS are now sifting through the thousands of comments to determine the final rules on stage one of the meaningful use incentive programs. So what are the comments saying and will they have any influence in the end? Check out what the organizations that at least have enough clout for ONC and CMS to really listen to, or read in this case.

The American Academy of Family Physicians (AAFP) represents nearly 95,000 physicians and medical students. They suggest offering partial incentives, making the first year Medicare and Medicaid programs more similar, allowing shorter reporting periods, and considering incentives for family physicians on hospital teams. Read their comments.

The College of Healthcare Information Management Executives (CHIME) represents 1400 top healthcare executives and based the comments on a membership survey. They have Critical Concerns as well as areas they feel need clarification. They all are not in favor of the “all or nothing” approach to incentive programs. Read their comments.

The Markle Foundation, Center for American Progress, and Engelberg Center for Health Care Reform at Brookings collaborate with 56 diverse organization to comment on both the ONC IFR and the CMS NPRM. The comments discuss their recommended priorities HHS should take in stage one. In particular, they would like the focus on health improvement goals,specific quality metrics, and consumer participation. Read the IFR Comments. Read the NPRM Comments.

Leading consumer organizations – AARP, the Center for Democracy and Technology (CDT), Consumers Union, the National Partnership for Women & Families, and a leading employer organization – the Pacific Business Group on Health also collaborated to comment in support of the rules urging them to keep the current rules as they are pro consumer (patient) oriented. Read their comments.

HIMSS Electronic Health Record Association engaged 28 vendor companies to compile their responses to the proposed rules. The group continues to claim the requirements are too many and don’t believe they can be met. Read their letter to the ONC. Read their letter to CMS.

To read all comments for either of the rules, search the online database at