The National Association of State Medicaid Directors (NASMD), with the aid of the Center for Health Care Strategies (CHCS) submitted comments to CMS regarding the Electronic Health Record Incentive Program proposed rules published in the Federal Register.

From the letter:

The HITECH provisions under ARRA established that the States will be responsible for much of the planning, implementation, oversight of electronic health records (HER adoption, and the statewide expansion of health information exchanges (HIE). CMS understands that in many cases, the Medicaid Program is driving statewide HIT provider adoption. State Medicaid agencies are charged with HIT planning, assessing provider

EHR readiness and planning adoption support, and developing the necessary Medicaid HIT infrastructure to support Medicaid participation in HIEs. Medicaid programs have a strong sense of responsibility and accountability for achieving the goal of meaningful use of EHRs in Medicaid. This endeavor will require dedicated and skilled Medicaid agency staff in order to achieve success. State Medicaid programs need continued support and flexibility if they are going to be able to implement HER incentive programs and assure meaningful use of EHRs by providers as early as January 2011. It is critical that CMS provide states with an adequate amount of resources, time, and technical assistance to plan and administer this major program.

Full letter: Comment Letter to CMS on EHR Incentive Program (PDF | 176.83 KB)

National Association of State Medicaid Directors. (2010). Comment letter to CMS on EHR incentive program. Kohler, A., Steckel, C. and Clark, L.