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Request for Comment on Recommended EHR Stage 2 Meaningful Use Objectives

January 27, 2011


Dear Colleague:


This advocacy request is different from the usual advocacy emails you receive from ASGE. Instead of asking for you to write your legislators, we would like your input in response to a request for comment (RFC) from the Department of Health and Human Servicesí (HHS) Health Information Technology Policy Committee (HITPC).


The HITPC is looking for clinician guidance on a preliminary set of recommendations regarding Stage 2 and 3 meaningful use objectives for the Electronic Health Record (EHR) Incentive Program. While this RFC includes objectives for Stage 3, at this time the HITPC is primarily interested in comments on the proposed Stage 2 objectives. The possible Stage 3 objectives were included to give context to some of the Stage 2 objectives.


ASGE is planning a comment letter and would like your input based upon your knowledge and experience to help shape those comments. The comments received by HITPC will be taken into consideration as HHS develops its proposed rule for Stage 2 EHR meaningful use, which is expected to be published this fall. Implementation of Stage 2 EHR meaningful use begins in 2013 and Stage 3 in 2015.


ASGE is most interested in your feedback on the proposed Stage 2 objectives along with your experiences in attempting to fulfill the Stage 1 objectives. ASGE shares the concerns of many in the physician community that HHS will move forward with proposing Stage 2 objectives without having completed a thorough analysis of successful participation by physicians in Stage 1 meaningful use.


ASGE requests that you submit your comments by February 15. Comments should be sent by email to Lakitia Mayo at


In the American Medical Association Meaningful Use Objectives Matrix, we have highlighted in purple those objectives on which ASGE would particularly like your feedback.


In addition to the proposed Stage 2 and Stage 3 objectives, the HITPC has also presented 10 questions in which they would welcome additional public comment. Among those questions, ASGE would be most interested in your responses to the following:


  1. What are providersí experiences with incorporating patient-reported data into EHRs? (e.g., data self-entered into personal health records)
  2. For future stages of meaningful use assessment, should CMS provide an alternative way to achieve meaningful use based on demonstration of high performance on clinical quality measures? (e.g., drug-drug interaction checking)
  3. Should Stage 2 allow for a group reporting option to allow group practices to demonstrate meaningful use at the group level?
  4. In Stage 1, as an option menu objective, the presence of an adverse directive should be recorded for over 50% of patients 65 years of age or older. We propose making this objective required and to include the results of the advance-directive discussion, if available. We invite public comment on this proposal, or to offer suggestions for alternative criteria in this area.
  5. What are the reasonable elements that should make up a care plan, clinical summary, and discharge summary?
  6. What additional meaningful-use criteria could be applied to stimulate robust information exchange?


I thank you in advance for your attention for this important request. We look forward to hearing from you.





 Brian Jacobson Sig Line

Brian C. Jacobson, MD, MPH, FASGE

Chair, ASGE Health and Public Policy Committee







Related Documents

         The HIT Policy Committee Request for Comment

         AMA Meaningful Use Objectives Matrix

         ASGE Top Concerns Conveyed to AMA on MU Recommendations

         ASGE Letter to HHS on Stage 1 Objectives

ASGE Resources

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