Meaningful Use Rule: Initial Comments Set the Tone

It’s been a relatively quiet week—the initial reactions to the proposed rules on “meaningful use” and standards are out, and the flood of commentary has temporarily subsided. The work of reviewing and analyzing the rules in depth has just begun, as staff at various industry organizations pore over the 700 pages of government verbiage at a more detailed level to evaluate how their respective stakeholders will be affected. We are actively participating in such conversations, and a number of leading organizations—MGMA among them—have reached out to us to talk about the implications for physicians. I hope that they will take our input into account as they formulate their recommendations.

Although it is anticipated that the vast majority of public comments will not be submitted until the final days of the 60-day comment period—i.e., in early and mid-March—individual physicians and others have begun formally registering their opinions. Not surprisingly, some of the initial comments reflect anger about the length and complexity of the rules themselves. Urging the government to keep the requirements simple was a common theme among comments from physicians and administrators:

“If the goal is to get the majority of clinics using EHRs and to provide incentive funds to help the economy, then the first step of incentive payments must be easy to obtain.” —Craig Brauer

“The ‘meaningful use’ criteria should provide incentives to encourage the implementation of the most essential features of an EHR, but it is imperative that the ‘meaningful use’ criteria not become a Christmas tree of features that becomes hugely expensive and unworkable. The ‘meaningful use’ criteria must not make perfect the enemy of the good.” —Robert Rauner, M.D.

Others talked about the limitations of traditional EHR products and issues of usability:

“I am concerned that the current emphasis, promoting adoption of existing EHRs, with little focus on the need to make EHRs better, will ultimately slow innovation. . . . Usability is the Achilles heel of current EHRs. An EHR may meet all of the functionality requirements and yet be so burdensome to use that patient care is made more difficult. . . . At this point we don’t need more EHRs, we need better EHRs.” —Christine Sinsky, M.D.

Objections to CPOE and the effect on physician productivity were also common:

“The process of entering orders is often inefficient and time consuming, with multiple screens, drop-down boxes, scrolls, and clicks. Assigning these clerical tasks to physicians results in a redirecting of limited physician resources away from clinical work, replacing direct patient care with low value added clerical work.” —Christine Sinsky, M.D.

To view these and other comments, or to submit your own recommendations, go to

On a lighter note, a few days ago, I read a parody in HIStalk (a venerable healthcare IT blog) called “Marry in Haste, Repent at Leisure: Choose Your EMR Soul Mate Carefully.” It compared purchasing an EMR to getting married, and the analogy is a good one. Mr. HIStalk, the blog’s author, postulated that “the same handful of wrong reasons that convince people to marry unwisely also convince them to buy EMRs that will make them unhappy.” If you are interested in reading more, go to HIStalk.

3 thoughts on “Meaningful Use Rule: Initial Comments Set the Tone

  1. Evan:

    I’ve been following your reports all along and I wanted to let you know how much we appreciate your steadfast and logical approach to the EHR maelstrom. Keep it up, we will prevail.

    Meaningful Use? Do you use it everyday, has it replaced 90% of your paper charts and is it cost-effictive. Done.

    Peter Hanson
    Cardiovascular Associates
    Wausau, WI 54401

  2. My hope is that SRS will critically analyze the data given and actively step forward in the software arena to assure that our system will indeed qualify for “meaningful use”.

    [From Evan Steele] It is not just the software that has to qualify for “meaningful use.” Each physician must earn the potential government incentives each year by meeting all 25 of the “meaningful use” measures that have been included in the proposed rule. SRS has done extensive analysis of the amount of time that it would take to meet and report on these measures and analyzed the cost of doing so. Using the productivity calculator (accessible on the upper right corner of the EMR Straight Talk page) you can value your physicians’ time, and will likely conclude that the cost of complying far exceeds the potential $44,000 return (an average of $8,800/year) from the government. The cost of this lost productivity is in addition to the $201,000 cost explained in my January 6th Straight Talk post, “The New Meaningful Use Rules: Is Participation Worth Your Time?

  3. This is one of the criteria for meaningful use…

    “…Implement five clinical decision support rules relevant to specialty or high clinical priority, including for diagnostic test ordering, along with the ability to track compliance with those rules… …We propose to describe clinical decision support as a health information technology functionality that builds upon the foundation of an EHR to provide persons involved in care processes with general and person-specific information, intelligently filtered and organized, at appropriate times, to enhance health and health care.”

    Does anyone know precisely what is meant by “Implement five clinical decision support rules?”

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