Comments on Proposed Rules for Stage 2 of the federal Electronic Health Record Incentive Program

CDT supports the use of electronic health records by health care providers and by patients to improve individual and population health.  However, federal incentives to promote electronic records must be accompanied by strong privacy and security policies and technical safeguards.

To be eligible for financial incentives, health care providers should be required to demonstrate compliance with strong baseline privacy and security policies, and their electronic health records should be equipped with technical capabilities that facilitate adoption of good security safeguards.

The attached document contains the comments CDT submitted supporting this position to the Centers for Medicare & Medicaid Services (CMS) and to the Department of Health & Human Services (HHS) on the proposed rules for Stage 2 of the federal electronic health record incentive program.


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