LCCR Comments on Electronic Health Records (EHR) Incentive Program–Stage 2 Proposed Rule

Executive Summary

�These comments from NHeLP and the Leadership Council address CMS’ program to pay incentives for Medicaid and Medicare providers to implement EHR data systems. The principal recommendation are that the rule reinforce current civil rights and health information privacy rules, require robust data collection for a variety of demographic categories, and create linkages with existing strategies to reduce health disparities

Marilyn B. Tavenner
Acting Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201
Farzad Mostashari, MD
National Coordinator for Health Information Technology
Office of the National Coordinator for Health Information Technology
U.S. Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201


RE: CMS?0044?P (Electronic Health Record Incentive Program?Stage 2 Proposed Rule), RIN 0991?AB82 (2014 Edition EHR Standards and Certification Criteria Proposed Rule)
Dear Acting Administrator Tavenner and National Coordinator Mostashari:
The undersigned member organizations and other supporters of The Leadership Conference on Civil and Human Rights appreciate this opportunity to provide comments in response to the proposed rules implementing Stage 2 of the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs, including the standards and implementation specifications that certified EHR technology would need to include to support meaningful use as of 2014 (file codes CMS?0044?P and RIN 0991?AB82). The Leadership Conference is a coalition charged by its diverse membership of more than 200 national organizations to promote and protect the civil and human rights of all persons in the United States (U.S.). The Leadership Conference?s Health Care Task Force is committed to eliminating health disparities and ensuring that all people in the United States can access quality, affordable health care, without discrimination.


The incentive program offers an important opportunity to reduce health disparities and improve equity in the U.S. health care system. Indeed, reducing disparities is included in the first of the ?five pillars? of meaningful use health outcomes policy priorities. We strongly
support the prominence given to this goal in the program?s structure; however, we are concerned that the meaningful use requirements as proposed are inadequate to achieve this outcome. We are at a critical juncture for ensuring that public investments in health information technology (IT) result in the reduction and ultimate elimination of disparities. If the Stage 2 criteria do not reflect a more robust application of health IT to increasing health equity, the federal government is in jeopardy of creating greater disparities as the majority of Americans begin to see benefits from health IT implementation.
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