The Centers for Medicare and Medicaid Services has received nearly 300 public comments on the proposed meaningful use rule, and officials expect a flood of comments as the March 15 deadline nears.
"I'm betting on 10,000 but it depends on what types of letter writing campaigns you folks start," Tony Trenkle, director of the CMS Office of E-Health Standards and Services, said during a presentation at the HIMSS 2010 Conference in Atlanta.
Trenkle encouraged his audience to get those comments flowing in, saying they form the basis for changes that result in a final rule. "We read all the comments, everybody's comment gets a hearing." The final rule remains on schedule for release in spring 2010, but likely in late spring, Trenkle said.
As for letter writing campaigns, Bill Braithwaite, M.D., former senior advisor on health information policy at the Department of Health and Human Services, discourages the mass mailing of templated comment letters from associations and other organizations.
There are two major types of comments that backfire and won't lead to policy changes, said Braithwaite, now chief medical officer at San Diego-based security software vendor Anakam, during an interview with Health Data Management. Nobody pays attention to "'I don't like this'" types of letters, he noted. "The fact is, nobody likes change."
But the other big mistake in making public comments is to send thousands of the same letter, Braithwaite said. Ten thousand identical letters will get counted as one comment letter. Asked why some attorneys and consultants advocate mass mailings, he replied, "I think it's a way for them to make money, but not a way to change the rule."
Braithwaite expects minor changes in the final meaningful use rule, but that doesn't diminish the importance of comments because they can fundamentally change some processes for administering the program. For instance, comments that show federal officials ways to automatically extract data necessary for reporting purposes "will be listened to."
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