Everyone wants to be heard. And, by all accounts, the providers and healthcare organizations that commented on the proposed rule for meaningful use Stage 2 weren't just wishing upon a star when they sent their carefully crafted comments to the Centers for Medicare & Medicaid Services for consideration.
They may not have gotten all the changes they wanted, but they believe the rulemakers listened. They felt understood.
Charles Christian, CIO of Good Samaritan Hospital in Vincennes, Ind., told Healthcare IT News Managing Editor Mike Miliard the rules "appear to have been thoughtfully considered, even the ones where the response was that the proposed objective stands as the final." (P. 12)
Christian said he was satisfied that CMS and ONC listened to the provider community, and took to heart - wherever practical - the input received during the comment period.
William Spooner, CIO of Sharp Healthcare in San Diego zeroed in on "a couple of wins" for providers - one of those wins was the three-month reporting period for Stage 2. It provides the needed flexibility providers need, he says. The rulemakers had proposed raising the reporting bar to 12 months.
It's exacting work - though perhaps more taxing today for its complexity rather than for its review method. Imagine getting all these comments on paper - and somehow sifting through all of them, trying to make sense of them and to respond in a coherent fashion.
That's what Elizabeth Holland, director of the HIT Initiatives Group in the Office of E-health Standards and Services at CMS, faced when see started her career with CMS more than 20 years ago. The work is still challenging today, but she and her colleagues can handle it more easily digitally than on paper. They just know to plan to work 24/7 during crunch time.
Each measure in the final rule is accompanied by a summary of the comments from stakeholders, followed by a decision from rulemakers, paired with an explanation, giving detail of just what the rulemakers were thinking, providing the answer to the "why."
"We feel very strongly about that," Holland told me in an interview for this month's NewsMaker feature (P. 46) "We feel that was our responsibility."
Holland knew providers would be disappointed that the rule regarding patient engagement remained, though in a weakened form, requiring that 5 percent rather than the proposed10 percent of patients view online, download or transmit to a third party relevant health information. Providers say it's out of their control. Holland says, "I have confidence they'll be able to do it."