Six weeks after posting an initial batch of 24 public comments on the proposed meaningful use rule on a government Web site for public viewing, the Department of Health and Human Services has posted another 83 comments. The comment period ends on March 15. Here's a sample of some of the new comments:

* "I endorse a majority of the proposed rules for the electronic health record incentive program. I am encouraged to see that CMS is helping to bring technology to health care to provide better services, tracking, and transparency to health care. I disagree with the section on physician order entry. To help make the move to electronic use, the entire medical team needs to be involved. As there are only services that can be provided by the physician and not the staff, it becomes onerous to insist that the clerical duty of computerized physician order entry be required to be by the provider, and not include the staff. This will slow the flow within the office and diminish the access to patient care by insisting that a clerical duty of data input for order entry be performed by the provider. To improve the quality of care and the access, I strongly encourage the use of the entire medical team, with oversight by the physician, to utilize the order entry function. I think this one area will become a large obstacle for the typical small offices, and be a hurdle for the intent of the electronic health record incentive program."

* "As a Certified Registered Nurse Anesthetist, I feel that EHR users should include non-physicians that also provide care and bill Medicare. Not having these important providers is a grave oversight on the part of CMS. I urge you to correct this and include other non-physician providers."

* "I am not sure if this is the correct rule regarding "meaningful use" criteria. It may be the ONC's Interim Final Rule. We are a pediatric clinic and we do a lot of immunizations, including under the Vaccines for Children (VFC) program. While we can track immunizations with our Electronic Medical Record very well, and we could do an enhancement to have one-way transfer of information to the state immunization registry (KSwebIZ - set-up in process), we cannot query the state registry (i.e., a two-way transfer) to find out if the child has received immunizations somewhere else. As it turns out, most EMR companies can only do one-way transfer of the clinician to the state. This leads to needless shots, use of vaccine and sometimes delays in administration of other vaccines. EMR vendors need to be required to set up this two-way immunization registry sooner (this phase of 'meaningful use' criteria) rather than later. This prevention medicine is the single most effective means of insuring the health of the population."

For more comments, click here.

--Joseph Goedert

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