More MU Comments Sent to CMS

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As the March 15 deadline for comments on the meaningful use proposed rule nears, additional commentary continues to pour in with some of them available here. Here are two examples:

* "Your regulations assume that robust IT infrastructure exists everywhere. Our primary care practice is located in a rural Appalachian area with a high percentage of elderly and poor who have minimal access to the Internet. Also, we have a large Amish population who shuns technology. Our pharmacies are Mom and Pop stores without the capability of e-prescribing. Our Internet connections are slow and subject to outages. We have offices in four rural towns and find it difficult to connect our IT infrastructure for simple billing functions. So, my comment is this.... We would like to implement EMR, but reliable, fast infrastructure has to happen first. We will eventually be penalized for practicing in a rural area because it has inferior IT infrastructure since we will be unable to meet your deadlines, due to infrastructure issues beyond our control. Reliable broadband is not available in my locale, yet I will be held accountable to the same rules as a physician in New York City. You need to make some way to account for variation in IT infrastructure that is beyond the control of rural providers who would like to participate yet cannot due to this disparity. It is the rural areas that are in greatest need of primary care providers, yet these are the areas with the worse IT infrastructure. Rural areas are also in need of primary care providers. Yet, your rules as proposed with financial incentives and then penalties will weaken our rural primary health care supply as they move to the city where infrastructure exists and they can better qualify for your incentives. Bottom line.... You need to provide all the financial incentives for rural docs to qualify and purchase EMR, but make appropriate adjustments for them so they can get EMR and start using it professionally, while hopefully the infrastructure (if ever) gets built."

* "Requiring EHRs to check insurance eligibility and submit claims electronically is an odd requirement. Most physician offices have a practice management system that performs these functions. Adding these functions into an EHR does not improve health outcome, while it unnecessarily burdens the physician. In a typical physician practice, the physician (primary user of EHR) is not responsible for insurance verification or claims submission. Adding this to the EHR and to the physician's workflow effectively slows the physician. Insurance companies usually require these checks. Government need not interfere with the payment process. I suggest this requirement be removed from the proposal."

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