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The Centers for Medicare and Medicaid Services is getting an earful from industry stakeholders about the proposed meaningful use rule.

An early sampling of published comments shows CMS has its work cut out trying to clearly define what is required of provider organizations; industry stakeholders also have pointed questions about the granular I.T. issues addressed in the massive proposed rule.

CMS will accept comments until March 15. Organizations and individuals can submit comments by accessing www.regulations.gov and selecting "proposed rules" under document type and entering "meaningful use" in the keyword box.

The display screen shows comments already posted and includes links to add a comment.

Following is a sampling of submitted comments.

Bureaucracy Run Amok

"You people are out of control government bureaucrats that need to be run out of town. Really, a 550+ page document just to propose a rule to hand out stimulus money? You are running this country into the ground with all your regulation of private industry and are the EXACT reason the USA can no longer compete on the global stage unless we're talking about who can print money and ruin their currency the fastest. In that case, we'd win."

Bureaucracy Run Amok II

"This is a steaming pile of crap. If one could imagine what the worst possible outcome of the process of creating these rules could be, this is it. These are rules that only a bureaucrat could love and will not help increase the implementation of EHR. 556 pages?! You are out of your minds if you think this is helpful or necessary. What a waste of time and money... This is so disappointing I almost cried."

CPOE

"I recommend that 'CPOE' (computerized physician/provider order entry) 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. While the physician is interacting with the patient the pharmacist enters any new medication orders and the nurse enters any new patient care orders. Decision support and efficiency are enhanced. The majority of 'decision support' screens are of limited value and are routinely clicked off without further consideration. With the pharmacist present significant medication expertise is shared in a more robust manner. The process of entering orders is often inefficient and time consuming, with multiple screens, drop down boxes, scrolls and clicks. Assigning these clerical tasks to physicians results in a redirecting of limited physician resources away from clinical work, replacing direct patient care with low value added clerical work. It would be unfortunate if hospital or clinic administrators interpreted 'CPOE' literally and mandated that orders only be entered by physicians. I recently shadowed physicians at an academic medical center where one of the ICU faculty commented: 'My residents have so much less time to spend with patients and can't get much work done because every morning the nurses hand them a stack of papers with orders from over night that the residents must enter into the computer.' I suggest it is best not to bake CPOE into the language of meaningful use, and instead recommend COE, which is more aligned with the goals of enhancing teamwork, organization and efficiency in healthcare."

CPOE II

"I am writing regarding the hospital measure for CPOE. The measure excludes orders entered by providers in the hospital operated Emergency Department. The Emergency Department is identified as POS 23 and as such is considered an outpatient facility and not eligible for inclusion into the CPOE measurement. The Emergency Department in many hospitals is the portal into the health care system and the inclusion of orders entered by EPs 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. The need to identify measurements based on location within the facility doesn't appear to allow for the adoption of the CPOE matrix without causing confusion among EPs. I would recommend a change that allows hospital based EDs to participate in the hospital objective and allow for electronic order entry that originates in the ED to be included in the hospital measure."

Interface Issues

"Organizations should not have to rewrite existing fully functional interfaces to comply with MU 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 submissions and HL7 2.3.1 for public health submissions. Redeveloping/retesting these interfaces, for no other reason than to bring it up to a current version, is a waste of resources. Please clarify this rule and change it so that existing working links can remain in place until there is a need to upgrade."

Ambulatory Surgery Centers

"As the Clinical Director of a physician practice I am excited about opportunities and incentives available to our practice related to our EHR. We have been using an EHR for two years and are continually expanding and improving our services through this technology. Our EHR is robust and interactive and I am confident will meet the Meaningful Use Requirements. I also serve as Clinical Director of our ambulatory endoscopy center. We have been using a specialized EHR in our endoscopy center for eight years. This dynamic product has enabled our physicians to communicate more effectively with our patients and providers, improve patient safety, consistently meet regulatory standards, manage equipment, improve infection control surveillance, and lower costs while maintaining quality care. This product has proven to be such a valuable asset that I find it distressing, under the current requirements for 'meaningful use,' that 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 ambulatory surgery environment. These are exciting times and all of us in healthcare have unprecedented opportunities to improve our services through technology. From personal experience, adoption of EHR improves the patient experience exponentially. Please consider the benefits specialty EHRs bring to the healthcare consumer as you continue to develop the EHR incentive plan."