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The initial proposal of a workgroup of the HIT Policy Committee to define meaningful use of electronic health records includes a matrix of about 55 functions, or elements, that should be phased in over several years. But under the proposal, 22 of the functions have to be achieved to some degree during the first year in 2011.

The College of Healthcare Information Management Executives suggests setting a specific number of functions that must be adopted each year from 2011 through 2014, rather than specific functions to be adopted by specific years.

"We would endorse an approach that enables each organization to pick a defined number of elements for each year where the elements represent any of the 55 total elements," the trade group representing CIOs said in a comment letter to David Blumenthal, national coordinator for health information technology. For example, 20 elements could be required in 2011, followed by 10 elements each in 2012 through 2014, according to CHIME.

The organization also expressed the need for far more clarity in what required functions really would mean. For instance, does "the exchange of key clinical information among providers of care," proposed for 2011 mean the actual interchange of data, or simply the ability to exchange the data?

Does the proposed use of CPOE in 2011 for all order types including medications mean all orders, or one of each order type? CHIME asked. "There is a significant difference in scale of effort to meet this requirement," according to the organization's comment letter.

CHIME's full comment letter is available at http://cio-chime.org/advocacy/CHIMELetterreMeaningfulUseJune26.pdf.

--Joseph Goedert