Comment on Meaningful Use
When the Centers for Medicare and Medicaid Services (CMS) finally released the long-awaited proposed definition of meaningful use
as it applies to electronic health records (EHRs), it opened up a 60-day public comment period. In the spirit of "full" disclosure, the government has posted some of these comments on a Web site.
Here are just a few of the comments released:
"I am writing to comment on the proposed Centers for Medicaid and Medicare rule administering the provider incentives to adopt electronic health records.
"Our association represents 113 primary care pediatricians in the Portland-Vancouver Metropolitan Area in Oregon and Southwest Washington. Our private practice pediatricians care for a quarter million children. About 70 percent of our pediatricians have electronic medical records (EMRs) and about 10 more will be adopting EMRs in 2010.
"My comment about your administrative rules is simple: the rules are far too complex and lengthy. This document is over 500 pages long! It appears to me that there will be more money going to regulate the disbursement of the dollars than actually going to provide incentives to physicians to adopt EMR. This is a disappointment both as the Executive Director of the association but also as a taxpayer. I hope you will consider cutting the length and complexity or you will be disappointed that few participate."
--Sharon M. Fox, Executive Director, Children's Health Alliance
"...Speech recognition software has become an effective and widely used part of Department of Defense and Veterans Health Administration medical programs, and we feel it should be adopted throughout our entire health care system.
"We urge you, therefore, that in order for eligible providers to be considered ‘meaningful electronic health records users' to qualify for payments under Medicare and Medicaid, they be required to use electronic records that provide for the inclusion of a physician narrative beyond the template text. We also urge you to assess the applicability of speech recognition technologies to help make electronic records more effective, detailed and productive. ..."
--Paul J. Kirk, Jr.
"I endorse a majority of the proposed rules for the electronic health record incentive program. I am encouraged to see that CMS is helping to bring technology to health care to provide better services, tracking and transparency to health care. I disagree with the section on physician order entry. To help make the move to electronic use, the entire medical team needs to be involved. As there are only services that can be provided by the physician and not the staff, it becomes onerous to insist that the clerical duty of computerized physician order entry be required to be by the provider, and not include the staff. This will slow the flow within the office and diminish the access to patient care by insisting that a clerical duty of data input for order entry be performed by the provider. To improve the quality of care and the access, I strongly encourage the use of the entire medical team, with oversight by the physician, to utilize the order entry function. I think this one area will become a large obstacle for the typical small office, and be a hurdle for the intent of the electronic health record incentive program."
--Thomas A. Raskauskas, MD, Midwest Medical Center, Dearborn, MI
For more comments, visit Regulations.gov.
The comment period ends on March 15, so don't delay in voicing your opinion.