Meaningful Use Stage 2 Requirements 60-day Public Comment

The long awaited and much anticipated proposed stage 2 meaningful use requirements is finally here for a 60 day public comment. It was posted on the Federal register after The Department of Health and Human Services Centers for Medicare and Medicaid Services (CMS) publication of their proposed rule for Medicare and Medicaid Electronic Health Record Incentive Program Stage 2 otherwise commonly known as Meaningful Use Stage 2. The public comments will begin 30 days after the publication as required by The Office of the National Coordinator for Health Information Technology (ONCHIT) and the Health Information Technology (HIT) Policy Committee. Although comments cannot be accepted through facsimile (FAX) transmission, they can be submitted through mail such as Regular, Express, Overnight, Hand Delivery or Courier services. One may also submit their comments electronically at the government requirements emr website.


The two rules which will solicit most comments are:

  • Medicaid and Medicare EHR Incentive Program which are an expansion and are consistent with the ones of stage 1
  • New and Revised Standards (e.g. tracking of online accesses by patients which can be viewed and downloaded or the transmission of events, human readable format of PHI like diagnostic test results, medication list, problem list, medication allergy list, procedures, clinical summaries and discharge instructions,), Implementation Specifications, and Certification Criteria for Electronic Health Record Technology (called Certified EHR Technology)

All comments received before the close of the comment period will be made available for public inspection. This simply means that if there is anything that you would not want the public to know about you or your organization, such as confidential personal or business information, you should not include it in the comment for the obvious reasons. This kind of openness is necessary in order to ensure that there is no biasness in the process of making this legislation considering the EHR systems majorly affect the public. This is the chance to congratulate the government’s efforts on the good aspects of the proposed rule and highlight the not so admirable aspects of it giving reasons and at the same time, making suggestions on what should be put into place. Providers are supposed to comment on the on 17 core measures and three out of five "menu" measures, of the proposed Stage 2 Meaningful Use which begins in 2014.

There is more precision and flexibility for physicians in this stage not forgetting the standardization for transportation and reporting of data between the different platforms of solutions offered by the various vendors. This can be clearly seen by the main focus of this stage which is on increasing the exchange of clinically relevant information between providers through their care transitions and increasing the electronic capturing of health information in a structured format. Physicians and patients are encouraged to communicate through text messages that is, the secure messaging or an encrypted mail. Patients are also expected to reach their health care information form physicians in a timely manner through electronic access. The rule further requires that more than 10 percent of their patients of any physician should respond via the secure messaging.