Comment on FR Doc # 2012-04430

Hello! I work for a chiropractic EHR vendor, and I have two concerns regarding new Stage II MU requirements. 1) Requiring that 10% of patients access their online health information seems to be something out of the provider's control. What if they cater primarily to the elderly? It takes meaningful use out of the hands of the provider and into the hands of the patient, whom the provider cannot control. Providers cannot mandate that their patients access their online information, therefore they cannot control their own compliance here. 2) Our chiropractors do not e-prescribe, nor do they handle medications, but are still required to assess medication and medication allergy lists and drug-drug/drug-allergy interactions. This means their systems are still required to have this capability, which is not in line with their practice and can also be costly for the small practice (whether developed by the EHR or contracted with a 3rd-party). I agree they should be able to view (via CCD/CCR) the medications prescribed by other doctors, but we get a great deal of feedback from clients who express that updating these lists takes time away from their relatively short visits with patients, considering they are not allowed to otherwise handle medications in their regular course of care. We were hoping for exemptions that addressed this issue in Stage II for our group of providers. Thank you so very much for your consideration.