Meaningful Use stakeholders: Speak your mind while the government is listening

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It's interesting that a number of common themes are emerging from the comments that have been submitted in response to the ONC Health IT Policy Committee's proposed recommendations for Stage 3 of the Meaningful Use program. A lot of the big stakeholders--organized provider groups, information technology societies, and the like--have expressed concern that the proposed requirements, due to go into effect in 2016, are too difficult to meet, inadequately protect the privacy and security of electronic health records, and can't be implemented in such a short time frame.

The American Medical Association said that the bar is being set too high and called for an independent evaluation of the program, a request also voiced by the American Hospital Association. The College of Healthcare Information Management Executives, meanwhile, said that the thresholds are unrealistic, while the American College of Physicians called them "overwhelming" and suggested that Stage 3 should measure improvements in healthcare outcomes, as opposed to functional measures.  

But note that these comments are receiving attention from the media because the organizations have issued press releases publicizing their positions. There actually have been 594 comments submitted in response to the Committee's request for comment. Most are buried on a government website, but still accessible, and come from individual physicians and state agencies, regional extension centers and consulting firms. 

That's a lot of comments, especially for what essentially was a trial balloon, and not an actual proposed rule.

Some of those comments are just as thought-provoking as the highly-publicized ones. For instance, the National Farm Medicine Center in Marshfield, Wis., recommended that Stage 3 include coded work and industry fields for all working patients, since clinicians don't often inquire about work-related physical and chemical injuries.  Futures without Violence requested changes in Stage 3 to improve screening and treatment referrals for incidents of domestic violence.

The Human Resources Center of Edgar and Clark Countries in Illinois asked that the Meaningful Use Incentive program be expanded to allow behavioral healthcare providers to participate.

We should give kudos to everyone who commented. Kudos also go to ONC and the Committee. They're trying to reach out and obtain feedback.

Not that I envy the regulators. It's a daunting task sifting through all of the comments, not to mention trying to determine how to respond, what to incorporate into the formal rule implementing Stage 3, and how to diplomatically reject a suggestion. Clearly ONC won't agree with all of them; the commenters don't even agree with each other.

And that's just these 594 comments. There surely will be many more, once the actual proposed rule is published in the Federal Register. The U.S. Department of Health & Human Services received 6,100 comments on the rule implementing Stage 2 of the program. The stakes now will be even higher, as the requirements are harder and the penalties for non-compliance will start kicking in.     

The Committee had stated when it issued its proposed recommendations that it will analyze the comments and hold further public meetings about Stage 3 in 2013 before formal rules are issued.

Sounds like stakeholders will have more than one opportunity to weigh in. Please take advantage of these opportunities.

Because once these rules are final, we all will have to live with them. - Marla (@FierceHealthIT)