Joseph Moore-IA

Document ID: CMS-2009-0117-0027
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: January 14 2010, at 12:00 AM Eastern Standard Time
Date Posted: March 2 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: January 13 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: March 15 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80a7da05
View Document:  View as format xml

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The requirements for meaningful use are too restrictive to be of any value to most specialty physicians. Only a complete EHR will provide the value we are all looking for. Primary care physicians are about the only ones that can take advantage of the incentives and therefore will be the only ones adopting EHR's. Specialty practices like radiology, oncology, and pathology all have something to contribute to a complete and comprehensive EHR. Leaving them out will only result in a lot of money spent with very little gained. There should be exemptions for each specialty physician category. For example radiologists don't perscribe medication so they should be excluded from eRX. On the other hand there are other objectives that should be included that are not in the rules for specialists. For example radiology practices should be required to export their images and reports to the ordering physician's EHR so that it can be a complete EHR. I think there's still a lot of work left to do to incentivise all necessary groups to participate.

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