The American Hospital Association submitted 68 pages of comments to the Centers for Medicare & Medicaid Services on Monday, arguing that the requirements proposed for meaningful use Stage 2 are asking too much.

 AHA Executive Vice President Rick Pollack wrote that the association agrees with federal efforts to accelerate the use of electronic health records. Yet, the CMS notice of proposed rulemaking, published in the March 7 Federal Register, asks too much, too soon of hospitals. “Taken as a whole, the proposed requirements for meeting Stage 2 raise the bar too high and are not feasible for the majority of hospitals to achieve,” he wrote.

According to Pollack, the vast majority of hospitals -- more than 80 percent -- have not yet met Stage 1, due to both the high bar set and market factors, such as accelerating costs and limited vendor capacity.

“Evidence also suggests that the digital divide is widening, with large and urban hospitals reaching much higher rates of adoption than smaller and rural facilities,” Pollack added. “Given the experience to date in Stage 1, the AHA is concerned that elements of the proposed rule for Stage 2 would stand in the way of a successful program to support widespread adoption by all hospitals.”

AHA officials said they are concerned that many of the proposals “put regulatory requirements ahead of actual experience” with technologies, an approach that will likely have unintended consequences.

[See also: Transaction technology critical to MU Stage 2.]

AHA had a number of concerns related to timing of the stages and the implementation of penalties for hospitals that have not adopted EHRs by 2015.

“The proposed approach to implementing the penalties that begin in fiscal year (FY) 2015 is unacceptable because it bases penalties on performance in a prior year, generally with a two-year look-back,” Pollack wrote. “This policy unfairly accelerates the date by which PPS (prospective payment system) hospitals must meet the meaningful use requirements to avoid penalties.”

The AHA said it appreciates the proposed one-year delay in the start of Stage 2, but it cautioned that the delay may not ensure adequate time for hospitals to transition from Stage 1 to Stage 2 safely and without “undue distortions to the market.”

AHA recommended two ways to ease the transition: a 90-day reporting period in the first year of Stage 2 and any subsequent stages, and a length of three years for each stage.

[See also: CHIME asks for more prep time for Stage 2.]

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