Comment on FR Doc # E9-31216

NOW THAT I'VE READ THE MEANINGFUL USE DEFINITION (25 STANDARDS / OBJECTIVES) THAT WAS RECENTLY PUBLISHED, IT SEEMS LIKE THE GOVERNMENT PULLED A FAST ONE (AGAIN) BY GETTING EVERONE EXCITED ABOUT THE OPPORTUNITY TO RECEIVE SIGNIFIANT DOLLARS TO PAY FOR THE IMPLEMENTATION OF EMR ONLY TO PULL THE RUG OUT FROM MANY PROVIDERS. WHY IS IT THE PROVIDERS WHO ALWAYS TAKE IT ON THE CHIN? WHY IS IT NOT THE EMR VENORS AND HIGHLY PAID CONSULTANTS, WHO HELP IMPLEMENT THE EMR PRODUCTS, BE HELD ACCOUNTABLE TO THE PROVIDERS WHO TOOK THE STEPS TO IMPLEMENT EMR BUT DID NOT KNOW THE CRITERIA THEY WOULD BE HELD ACCOUNTABLE TO UNTIL AFTER IT WAS TOO LATE. IT'S LIKE THE OLD ADAGE, READY FIRE AND SEE IF YOU HIT ANYTHING. TO INSIST THAT PROVIDERS ARE 100% COMPLIANT WITH THESE 25 STANDARDS 80 % OR WHATEVER THE CRITERIA IS FOR EACH OBJECTIVE IS NOT FAIR. IF PROVIDERS WOULD HAVE HAD THE CRITERIA WHEN THEY DESIGNED AND IMPLEMENTED THEIR WORKFLOWS, IT WOULD HAVE BEEN A MORE LEVEL PLAYING FIELD. I'M SUGGESTING THAT SOME CONSIDERATION BE GIVEN TO THOSE PROVIDERS WHO ALREADY IMPLEMENTED THEIR SYSTEMS AND ARE NOW STRUGGLING TO MODIFY SOME OF THEIR WORKFLOWS IN ORDER TO MEET THE NEWLY PUBLIZED MEANINGFUL USE CRITERIA. ALL THE VENDERS AND CONSULTANTS CARED ABOUT IS IMPLEMENTING BASED ON HOW THE PROVIDER WANTED TO OPERATE THEIR OFFICE AND NOT ACCORDING TO WHAT IS NOW NECESSARY IN ORDER TO MEET THE MEANINGFUL USE CRITERIA.