Comments to CMS about Meaningful Use

Jan. 27, 2010

“Organizations should not have to rewrite existing fully functional interfaces to comply with MU criteria. This will add a great deal of unnecessary cost. For example we already submit lab results and surveillance data to public health agencies using an older version (HL7 2.2). The new criteria calls for a minimum of HL7 2.5.1 for lab submissions and HL7 2.3.1 for public health submissions. Redeveloping/retesting these interfaces, for no other reason than to bring it up to a current version, is a waste of resources. Please clarify this rule and change it so that existing working links can remain in place until there is a need to upgrade.”

“As the Clinical Director of a physician practice I am excited about opportunities and incentives available to our practice related to our EHR. We have been using an EHR for two years and are continually expanding and improving our services through this technology. Our EHR is robust and interactive and I am confident will meet the Meaningful Use Requirements. I also serve as Clinical Director of our ambulatory endoscopy center. We have been using a specialized EHR in our endoscopy center for eight years. This dynamic product has enabled our physicians to communicate more effectively with our patients and providers, improve patient safety, consistently meet regulatory standards, manage equipment, improve infection control surveillance, and lower costs while maintaining quality care. This product has proven to be such a valuable asset that I find it distressing, under the current requirements for ‘meaningful use,’ that ASC-specific EHRs may not be eligible for consideration. I strongly urge you to include these essential information systems for their unique contributions to ‘meaningful use’ in the ambulatory surgery environment. These are exciting times and all of us in healthcare have unprecedented opportunities to improve our services through technology. From personal experience, adoption of EHR improves the patient experience exponentially. Please consider the benefits specialty EHRs bring to the healthcare consumer as you continue to develop the EHR incentive plan.”

“Regarding the requirement to report to public health agencies: The regulation should require that the hospital be prepared to perform the test as defined in various required areas. There is no specification of what public agencies are included nor any known requirement that the public agencies will be prepared to receive the information even in a test situation. Hospitals should not be penalized for others’ inability to participate. State budgets are very limited and I am concerned that they will not be prepared to receive this information electronically. Regarding system certification: I urge that any requirement for hospitals to use specific vendors, releases from vendors, or other proprietary products not be included in the ‘certification’ process. The only issue that should be considered is whether or not the requirements can be met. Our vendor, Meditech, has not had its release 5.4 ‘certified’ as being able to meet meaningful use standards, but is capable of performing what is being required. If hospitals on release 5.4 were required to upgrade to versions 5.6 or 6.0, Meditech could not meet the demand from its broad customer base. Hospitals have also developed internal electronic records that will meet the need, but not fit into a clean mold that proprietary entities look for in certification programs. There should be no reference to any specific product in determining whether or not a hospital meets the meaningful use standard.”

“I recommend that ‘CPOE’ (computerized physician/provider order entry) be changed to ‘COE’ (computerized order entry) eliminating the perception that the physician should be/must be the particular healthcare worker who physically types in the orders. In our hospital we have recently initiated collaborative rounds, with the physician, charge nurse, primary nurse and pharmacist rounding together, bringing together different domains of expertise and knowledge at the bedside. While the physician is interacting with the patient the pharmacist enters any new medication orders and the nurse enters any new patient care orders. Decision support and efficiency are enhanced. The majority of ‘decision support’ screens are of limited value and are routinely clicked off without further consideration. With the pharmacist present significant medication expertise is shared in a more robust manner. 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. It would be unfortunate if hospital or clinic administrators interpreted ‘CPOE’ literally and mandated that orders only be entered by physicians. I recently shadowed physicians at an academic medical center where one of the ICU faculty commented: ‘My residents have so much less time to spend with patients and can’t get much work done because every morning the nurses hand them a stack of papers with orders from over night that the residents must enter into the computer.’ I suggest it is best not to bake CPOE into the language of meaningful use, and instead recommend COE, which is more aligned with the goals of enhancing teamwork, organization and efficiency in healthcare.”

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