May 7, 2012 - On May 4, the American College of Radiology (ACR) submitted comments to the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for HIT (ONC) regarding the agencies' March 7, 2012, proposed rules to revise and update the professional and technology requirements of the EHR Incentive Program (“meaningful use”). The ACR IT and Informatics Committee (ITIC) - Government Relations Subcommittee compiled the comments with feedback from ACR members, allied organizations and other stakeholders.
“ACR’s comments provide realistic recommendations for how the agencies can improve the regulations from the perspective of diagnostic radiologists, interventional radiologists, radiation oncologists and nuclear medicine physicians,” said Khan M. Siddiqui, M.D., chair of the ACR ITIC. “We believe that if CMS and ONC incorporate these suggestions in the final rules, the program will be much more flexible and ultimately better for our patients."
CMS’ proposed rule suggests modifications to Stage 1 meaningful use requirements, potential Stage 2 requirements, new clinical quality measures, timelines for avoiding the future penalties for noncompliance and more. ONC’s proposed rule suggests a long awaited change to the definition of “certified EHR technology” that would eliminate many unused but currently required HIT functionalities.
ACR’s consolidated summary of both proposed rules is publicly available online.
“We hope ACR’s latest recommendations to CMS and ONC will have the same positive impact they had on the original 2009-2010 meaningful use rulemakings,” said Keith J. Dreyer, M.D., chair of the ITIC-Government Relations Subcommittee. “We will continue our advocacy efforts and collaborative activities with allies to increase the likelihood of a desirable outcome — but ultimately, it is in the hands of the regulatory agencies.”
CMS and ONC will review all submitted public comments over the next several weeks and begin work on the final rules, which are expected to be published in late summer-early fall 2012.
ACR’s comments:
Additional resources:
ACR summary of the March 7, 2012 NPRMs
July 25, 2024 
