I can't imagine what the CMS and ONC review committees are going through right now. My head is spinning, and I don't even have to read every last word of all the public comments on the proposed rule for meaningful use of EMRs or the interim final rule on standards and certification of EMRs, much less incorporate the comments into final regulations that have been promised in the next three months.
The comment period on the CMS proposal and the ONC interim final rule closed Monday, and I'm sure the folks in Washington are up to their eyeballs in work right now.
I base that assessment on the number of press releases, media advisories and comment documents themselves that have poured into my email inbox in the last week or so. FierceEMR and FierceHealthIT reported on the opinions of some organizations already, notably the College of Healthcare Information Management Executives and the Healthcare Information and Management Systems Society. But what's come in just under the deadline is too much to summarize in one column.
I will, however, make an attempt to run down some general themes. Provider organizations--notably the American Academy of Family Physicians, which commented about two weeks ago--want partial credit for partial progress.
Consumer groups have their own goals. We heard this week from a coalition consisting of the AARP, the Center for Democracy and Technology, Consumers Union, the National Partnership for Women & Families and the Pacific Business Group on Health, which called on CMS not to weaken the rules, lest the massive federal investment be wasted. An even larger coalition, 56 groups led by the Markle Foundation, the Center for American Progress and the Engelberg Center for Health Care Reform at the Brookings Institution, want CMS to focus on health improvement goals, specific quality metrics and consumer participation.
On the vendor side, the HIMSS EHR Association wants CMS to endorse standards recommended by the Health IT Standards Panel, and to clarify many of the specifications, but not increase the number of requirements. "The sheer number of requirements, and their complexity, could cause a provider that is doing everything right to miss the incentives based on small oversights or elements beyond their control, says EHRA Vice-chair Mark Segal of GE Healthcare.
That's a lot to digest. I don't envy the review committees or CMS and ONC staffers. - Neil