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When the meaningful use workgroup of the HIT Policy Committee on June 16 released its initial draft look at a definition, the first objective listed for possible criteria in 2011 was the use of computerized physician order entry for all order types including medications.

That's too tall an order too quickly, and should be deferred to 2013 or beyond, says the Association of Medical Directors of Information Systems in a comment letter to the Office of the National Coordinator for Health Information Technology.

"Implementing full CPOE is an important but complicated undertaking fraught with potential unintended negative consequences if done too quickly or incorrectly," according to the letter. "Even in the hands of our most experienced members working in organizations with EHR systems that are already up and running, successfully implementing robust CPOE functionality is generally a challenging, multi-year undertaking that requires careful planning and execution."

"Ambulatory e-prescribing is a notable CPOE exception that we are comfortable recommending for 2011 because it is a mature enough technology to be reasonably considered 'ready for prime time' and will have a sufficiently impactful effect on quality and cost to be worth striving for," the Lake Almanor, Calif.-based association added. Other recommendations include:

* Meaningful use "as seen through the patient's eyes" should specifically inform objectives and measures.

* Clarification is needed for payment under the stimulus law for meaningful use. It is unclear whether payment will require meeting some or all of the objectives, measures, or both.

* Keep 2011 objectives and measures sharply focused on demonstrated evidence of appropriate EHR data capture and sharing.

* Defer reporting of quality measures until 2013 when appropriate data capture and sharing should be in widespread use.

* Permit meaningful use incentives based on organizations demonstrating they meet expectations for sending and receiving data, regardless of whether trading partners can do so.

Full text of the AMDIS comment letter is available at meaningfuluse.org/Portals/0/AMDIS Response.pdf.

--Joseph Goedert