I’m finding the task of providing ONC with feedback on their recently published Meaningful Use Interim Final Rule very difficult. It’s not that I have nothing to say (quite the contrary). The challenge is how to format my feelings about the rule in a way that it will be effective and useful.
The problem with much of what’s being done with meaningful use and the EMR stimulus is that they’ve made it far too complicated for a small doctors office. Considering small doctors offices make up a large part of the healthcare in the US, that means that the EMR stimulus will do little to stimulate these doctors to start using an EMR. I could certainly make drastic recommendations about how they could change the meaningful use definition to solve this problem. However, it would require drastic changes. The likes of which are not likely to see the light of day nor affect any actual change on what’s been and will be published when the rule is completely finalized.
I don’t think that being able to say “I told you so” after the fact is enough reason for me to propose drastic changes if they’re not going to be able to implement drastic changes to the legislation.
So, this leaves me with the option of trying to provide more specific and detailed feedback on what’s been proposed. Essentially suggesting small changes that could be done to improve specific details. These things might be considered and implemented, but considering the other major flaws will likely make a small difference in the actual regulation.
I’ll admit I’m a bit torn by this dilemma. As I write this, it seems like the best option is to combine the two options. Preface my feedback to the EMR stimulus with a caution related to the overall affect of the stimulus as it’s been designed. Then, follow up with specific commentary that will hopefully simplify and improve the rule for those who choose to try for the stimulus money.
For those who are interested in providing feedback, you can do so on Regulations.gov. Just do a search for “CMS-0033-P” and you’ll find it.