The Centers for Medicare & Medicaid Services should work to develop the mature standards and infrastructure needed for efficient and effective health information exchange, and refrain from finalizing Stage 3 requirements for meaningful use of electronic health records until it has more experience with Stage 2, AHA told the agency in comments submitted today. “While the Stage 3 proposals offer promising ideas that could further health information exchange and support greater patient engagement,” 2015 will be the first year at Stage 2 meaningful use for most hospitals and the vast majority of physicians, wrote AHA Executive Vice President Rick Pollack. “The transition to new technology supporting Stage 2 has been a challenge for providers due to lack of vendor readiness, mandates to use untested standards, insufficient infrastructure to meet requirements to share information and compressed timelines. It also has proved extremely expensive – the AHA estimates that between 2010 and 2013 hospitals collectively spent $47 billion each year on information technology. We greatly appreciate the changes CMS has proposed in a separate modification rule for 2015 to 2017 that would accommodate some of the challenges, such as a shorter reporting period in 2015. However, the need for those changes in the middle of a program year underlines the importance of ensuring that policies are feasible before they are finalized in regulation.”