ACR, HIMSS weigh in on MU stage 3 requirements

CMS issued a proposed rule on stage 3 meaningful use (MU) requirements of its electronic health record (EHR) incentive program on March 30. With the 60-day comment period coming to a close, numerous groups—including the American College of Radiology (ACR), Healthcare Informations and Management Systems Society (HIMSS) and Medical Group Management Association (MGMA)—have weighed in on the proposed rule.

In a letter signed by Bibb Allen Jr., MD, FACR, chair of the ACR Board of Chancellors, and Keith Dreyer, FACR, chair of the ACR Commission of Informatics, the ACR repeated its request for an “attestation-based” alternative process for eligible professionals (EPs) who primarily work out of hospitals.

In addition, the ACR believes a reporting period of one year is too long for participants, instead suggesting a period of 90 days.

“The ACR recommends that CMS implement a 90-day reporting period for all MU participants every year,” the ACR wrote in its letter. “This would increase overall participation and reduce the disrupting impact of MU planning and compliance on future first-year participants.”

The ACR supports the CMS’s continued focus on clinical decision support (CDS) and the various exclusions included in the proposed rule, but does ask for revised requirements in regards to patient engagement. Instead of requiring more than 25% of unique patients to engage with the EHR, for instance, the ACR suggests a much smaller number, as has been discussed for earlier stages of MU.


HIMSS released its own comments in a letter signed by Paul Kleeberg, MD, HIMSS board chair, and H. Stephen Lieber, HIMSS president and CEO. The organization first stated that its research shows the positive overall impact MU has had on electronic medical records (EMR) throughout the healthcare sector.

“We have observed that over 70% of the hospitals we track have positively advanced their EMR capabilities over the last 5 years, while over 60% of hospital-tethered ambulatory facilities have realized a positive progression in just that last 3 years,” HIMSS wrote in its comments. “The increase appears to be an affirmation of positive impacts from the Meaningful Use program, and organizations’ collective willingness to engage in the program as a foundation for improving the quality and cost effectiveness of care delivery in the United States.”

However, HIMSS is concerned that EPs will not have enough time to completely adjust to the requirements of MU stage 3, estimating that it takes a full 18 months to properly make that transition. The organization also came out against the full year of reporting, recommending 90 days, also suggested by the ACR.

HIMSS shares another opinion with the ACR: it believes the proposed rule’s patient engagement requirements are too much. The organization is “encouraged” by CMS’s dedication to patient engagement, but worries about the sharp increase in various requirements from MU stage 2 to stage 3.

HIMSS also brings up the importance of proper security and pushes for providers to receive assistance from CMS with where and how to obtain security updates when necessary.


MGMA submitted comments in a letter from its president and CEO, Halee Fischer-Wright, MD. In the letter, MGMA pushes for CMS to “significantly modify” its proposed rule and says CMS has “created an extremely demanding set of requirements.”

“Should the qualifications for participation in these incentive programs be overly stringent or the process too onerous, the government runs the risk of excluding a large percentage of physician practices from participation in the program and unfairly subjecting EPs to penalties,” MGMA wrote in its comments.

MGMA thinks MU stage 3 should be delayed for now until the impact of the Medicare Access and CHIP Reauthorization Act of 2015—which will condense existing quality reporting programs—is known, and until more information is available about stage 2 participation. MGMA believes stage 2, as a result, should be extended through 2019. In addition, the association states that an EP’s ability to attest should not be contingent of the actions of patients or third parties.

Also, MGMA suggests a 90-day reporting period instead of the full year, repeating sentiments shared by both the ACR and HIMSS, and shares HIMSS’s concerns about needed guidance on security.

“Practices require guidance on where to obtain security updates and how to correct deficiencies exposed through the analysis,” MGMA wrote in its comments.