The comment period is drawing to a close on two important rules impacting our industry. The CMS notice of proposed rulemaking on the “meaningful use” EHR incentive program, and the ONC’s interim final rule describing the certification criteria for EHRs that qualify for the meaningful use program were issued on January 13, 2010. Both rules were subject to a 60 day comment period giving the industry time to comment on rules that will have a profound impact on healthcare IT. That time ends on Monday, March 15th.
CMS and ONC have worked hard to develop these rules, but they don’t live in the trenches. Your feedback is critical to make sure that these rules realistic and that the incentives will be attainable.
There is no need to start reading the rule now, or pulling an all-nighter to prepare your comments. Industry organizations such as CHIME, HIMSS, and the AHA have all prepared comments that can be used as a template. State Hospital Associations and vendors may be good sources as well. Below are links to several industry resources. Feel free to use them as is, or modify to meet your specific needs. Whatever you do – get your comments in by Monday!
AHA Resources: http://www.aha.org/aha/issues/HIT/100226-hit-meaningful.html
HIMSS Resources: http://www.himss.org/advocacy/
AHIMA Resources: http://www.ahima.org/ARRA/