It’s finally here! The Centers for Medicare & Medicaid Services (CMS) issued its draft definition for the “meaningful use” of electronic health records (EHRs) as part of its notice of proposed rulemaking (NPRM).  This 565-page document outlines the proposed implementation of incentives to providers for the adoption and meaningful use of certified EHRs.  The publication date is set for release in the Federal Register January 13, 2010, which will start a 60-day public comment period to help inform its development of the final 2011 meaningful use criteria.

Also released was an interim final rule (IFR) on Standards & Certification Criteria for EHR technology, which outlines criteria for “certified” EHR systems, and what technical specifications are needed to support secure, interoperable, nationwide electronic exchange and meaningful use of health information.  These certification standards were developed in accordance to the meaningful use criteria.

As quoted from the ONC Health IT Buzz Blog: “As part of the rulemaking process, the Standards & Certification Criteria IFR will go into effect 30 days after publication.  There will be an opportunity for public comment for 60 days from publication, after which the rule will be finalized.” It will be interesting to see how the public will react once the NPRM for meaningful use and the IFR for certification standards are open for comment.

Judging by the comments already up on the Health IT Buzz Blog, there are strong voices that are bringing up very important issues in response to the proposed meaningful use and certification criteria. As a summary, the major concerns brought up in the comments include:

  • Creating meaningful use standards from the physician’s frame of mind.
  • Addressing the conflict that a blanket set of requirements will not be applicable to all specialists and primary care physicians. Suggestions include making specialty-specific standards; or offering exclusions of specific requirements based on medical specialty.
  • Holding EHR vendors responsible for creating a product that will not only meet such meaningful use requirements, but also have the usability and functionality that medical practices need to be efficient and productive.
  • Creating a more easily read and understood document to summarize the main points of meaningful use and certification criteria. Who can read- and most importantly understand- over 600 pages of legislative verbiage?

Physicians are on the front-line of widespread EHR adoption. From the mere 14 comments on the HHS blog, I get the impression that physicians are supportive of EHR adoption, but fear that their voice is not being heard and/or supported in the design of the meaningful use and certification standards. As the proposed meaningful use and certification standards go up for public comment in a few days, I hope the physicians-and any other involved entity- can truly voice their opinions, be heard, and be considered by the Federal government before EHR standards are finalized.