As part of the effort to make the meaningful use proposal process transparent, the Centers for Medicare & Medicaid Services (CMS) has published the ongoing comments submitted on the Office of the National Coordinator for Health IT’s interim final rule and notice of proposed rulemaking on an open-access Web site.

As of press time, the Web site had 24 comments posted on topics including HL7, computerized provider/physician order entry (CPOE) systems and EHRs.

A sampling of summarized comments on various proposal topics is provided below. (Please note that the comments below are the opinions of the submitters.)

CPOE:

• To count as CPOE, must the provider personally (hands on keyboard) enter the order, or may physical entry of the order under the provider's direction be done by other staff? Must other staff be licensed, or would MAs qualify?
• Regarding the hospital measure for CPOE, the measure excludes orders entered by providers in the hospital operated emergency department (ED). The ED is identified as POS 23 and as such is considered an outpatient facility and not eligible for inclusion into the CPOE measurement. The ED in many hospitals is the portal into the healthcare system and the inclusion of orders entered by EP should be allowed to be counted towards the hospital measurement. It can become difficult to differentiate order entry by location when order entry is funneled into a central EHR or clinical results reporting system.
• How does anyone propose to measure the total orders by an eligible provider? This could be a time consuming and problematic exercise for any eligible provider or hospital.
• I recommend that CPOE be changed to COE (computerized order entry) eliminating the perception that the physician should be/must be the particular healthcare worker who physically types in the orders. In our hospital we have recently initiated collaborative rounds, with the physician, charge nurse, primary nurse and pharmacist rounding together, bringing together different domains of expertise and knowledge at the bedside.

EHRs:

• 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.

HL7:

• Organizations should not have to rewrite existing fully functional interfaces to comply with meaningful use criteria. This will add a great deal of unnecessary cost. For example we already submit lab results and surveillance data to public health agencies using an older version (HL7 2.2). The new criteria calls for a minimum of HL7 2.5.1 for lab submission and HL7 2.3.1 for public health submission. Redeveloping/retesting these interfaces, for no other reason than to bring it up to a current version, is a waste of resources. Please clarify or change the rule so that existing working links can remain in place until there is a need to upgrade.