Comment on FR Doc # 2010-04991

Our organization has been funding clinical information systems since the 1980's, and because of this, we are better prepared than most to meet the meaningful use requirements, and are currently under going the final certification audit to be consider a Level 6 adopter of emr technology as defined by HIMSS. This level of readiness, however, has take a lot of time and resources to achieve, and a lot of work and effort from the clinical system vendors we use. My main concern is how the funding appears to be front loaded, with the single largest incentive payment being tied to the 2011 criteria. While I totally agree with the goals and objectives, I am concerned that even if providers are ready to meet the schedule, many vendors cannot, and would suggest that you consider combining the 2011 and 2013 goals together, so that providers could qualify for the first or both by the end of 2013, then decrease the remaining payment representing the planned 2015 criteria, providing the industry with some "breathing room" to get the systems in place, but still within the timeframe of a 2015 end date....I think the sense is that many providers will "scramble" to select any vendor who promises to do an install within the 2013 "window", and not select the best solution....which will also have an unintended result of expanding/maintaining the number of emr vendors rather than a consolidation of them, something that the regulations should be encouraging, even if indirectly....thank you for your consideration....