In a move of more transparency the government (CMS) has made the comments on meaningful use public. You can find the comments on the Regulations.gov 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.