Government Makes Meaningful Use Comments Public

In a move of more transparency the government (CMS) has made the comments on meaningful use public. You can find the comments on the site. So far there have only been 24 comments made. Granted, there’s still a month available for people to comment.

CMIO has done a summary of the EHR comments:

  • I find myself discouraged that we will ever be able to comply with this meaningful use definition. I also reflect on the last eight years of using the EHR and wonder how a new user of an EHR would qualify as well. Just installing and getting everyone using electronic records is a difficult task. So I believe that this version of meaningful use is too aggressive for the first year.
  • We have been using a specialized EHR in our endoscopy center for eight years…I find it distressing, under the current requirements for meaningful use, ambulatory surgery center (ASC) specific EHRs may not be eligible for consideration. I strongly urge you to include these essential information systems for their unique contributions to meaningful use in the ASC environment.
  • Regarding requirement to patient access to EHR within 48 hours, patients may have multiple encounters with a hospital prior to the development and implementation of an EHR. There should be no requirement to provide an EHR prior to the implementation of the EHR system … Hospitals should not be expected to provide EHRs to non-covered organizations or to those who do not have the capability of receiving the information. This should be covered by separate regulation that impacts these facilities

CMIO also have some comments on the CPOE and HL7 components of meaningful use at the link above. I love this sort of transparency and we’ll be keeping an eye on the comments made. I wonder if the people submitting the comments realized that they’d be made public. Maybe it should be understood, but still feels a little off to just make them public when they weren’t previously. Hopefully we have more than 24 comments a month from now. I’m thinking that I’ll make a bunch of individual comments (maybe I’ll do 24 myself). I’m all about transparency and so I think I’ll post them on here as I send them to the government. I think my first submission will be these thoughts on Meaningful Use and then follow it with my own thoughts on the harmful effects of meaningful use.

About the author

John Lynn

John Lynn

John Lynn is the Founder of the, a network of leading Healthcare IT resources. The flagship blog, Healthcare IT Today, contains over 13,000 articles with over half of the articles written by John. These EMR and Healthcare IT related articles have been viewed over 20 million times.

John manages Healthcare IT Central, the leading career Health IT job board. He also organizes the first of its kind conference and community focused on healthcare marketing, Healthcare and IT Marketing Conference, and a healthcare IT conference,, focused on practical healthcare IT innovation. John is an advisor to multiple healthcare IT companies. John is highly involved in social media, and in addition to his blogs can be found on Twitter: @techguy.


  • John… I think that because this is a public comment period on the regulatory guidance that its a requirement that the public is able to see what is being posted… so HHS isn’t being othewise “transparent” than they are already required to be.

    Navigating to the website is fairly simple and might be very valuable to keep an eye on posts and keep an account of where comments are made.

    Very clearly you have a uniquely broad understanding of both the technical challenges of an EHR/EMR along with good understanding of how the practice or hospital operations are affected as well.

    We need to also keep an eye on what HHS panel of experts is getting … and what they are doing to identify and fix any “potentially harmful unintended consequences”.

    I got to find a link to that listing.

  • Sure, I figured that comments made to government could be made public. I just wonder if everyone submitting it knew that the public would be watching. Makes you wonder how large EMR vendors will submit comments. Will they do it as themselves?

  • John,

    The regulations website makes it clear that the information is public.

    “Any information (e.g., personal or contact) you provide on this comment form or in an attachment may be publicly disclosed and searchable on the Internet and in a paper docket and will be provided to the Department or Agency issuing the notice.”

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