Reporter's Notebook: Are You Kidding Me?

COMMENTARY: When the HIT Policy Committee first released it recommendations for meaningful use of electronic health records last June, I took one look at the matrix of requirements and thought, "Are you kidding me? Are you kidding me?"

I had the same thought after the committee reconsidered its recommendations for a month and came back with essentially the same thing in July. Ditto in December, when the proposed meaningful use rule came out.

An over-reaction? Maybe. But I dare you to take the matrix of requirements for eligible providers to your primary care physician. Bring along section 495.8 of the proposed rule, all 20-odd paragraphs on page 1995 of the Federal Register that discuss how physicians are expected to demonstrate meaningful use. Then wait a day or two and call back for a reaction. You'll see what I mean.

The HIT Policy Committee, officials in the Department of Health and Human Services and their support staff and workgroups faced a huge task getting the proposed core meaningful use rule out. They were racing against a quick congressionally imposed deadline that was nearly impossible to meet.

One has to admire and respect the yeoman's work they did. But one can't help but have a gnawing feeling while reading the rules that its requirements are simply undoable for far too many small hospitals and physician practices - the ones who most need to get on the EHR bandwagon.

The intent of the incentive program is to spur accelerated adoption of EHRs; but I fear the meaningful use requirements under will discourage many providers from even trying.

Maybe one reason is the membership of the HIT Policy Committee, the accomplishments of its members notwithstanding. A full 75 percent of committee members don't work day-to-day in the trenches of care delivery and none clearly represents the small hospital or physician view.

It isn't that realistic requirements weren't being considered. Speaking at HDM's Health IT Stimulus Summit last September in Boston, David Hunt, M.D., chief medical officer in the Office of the National Coordinator for Health Information Technology, said the government intended to implement a basic level of initial criteria for meaningful use. Hunt said the definition of meaningful use must focus on goals that hospitals and physicians "can achieve quickly and reasonably." He said federal officials primarily would be seeking evidence in 2011 that providers have purchased and are using EHRs. Hunt was dead on in one respect - that's pretty much the initial threshold for Medicaid incentives. But the Medicare threshold, from the start, goes well beyond.

Time remains to comment on the direction of EHR meaningful use and to inject realism into the debate before federal officials write a final rule. Whether you like the rule or not, the time to get changes is now as the March 15 deadline for comments will come quickly.

If you work at a small hospital or physician practice and see these requirements as unrealistic, you need to band with peers to get your voices heard. You need to find out what your trade associations are doing and the degree to which they will go to the mat for smaller provider organizations. And you need to move fast before the regulatory steamroller runs over your business.