I don’t have the expertise to fully comprehend these NPRMs that were recently issued, but did spend the last few hours reading large chunks of all three. The area they cover is huge, and I fear open source and small EHRs are about to lose big, and big corporate EHRs are about to get total lock-in courtesy of our government.

The bills cover a lot of territory, proposing many requirements that I do not think support “meaningful use” requirements. There are numerous interesting items, one surprising to me was that the ONC expects a Certified EHR will cost $163 million over 3 years to develop, excluding costs for testing and certification. The majority of the NPRM is framed with that mindset.

The ONC-HIT proposes a single certification body (who could’ve guessed) and expects only 3 vendors to apply for certification during the initial phase because of the cost and complexity of meeting the Certified EHR requirements.

If anybody knows how to read and respond to these types of things I suggest you do it now. Public comment period is very short, ends 3/15/2010.

References:
http://edocket.access.gpo.gov/2010/E9-31216.htm
http://edocket.access.gpo.gov/2010/E9-31217.htm
http://healthit.hhs.gov/portal/server.pt/gateway/PTARGS_0_11673_910783_0_0_18/ONC_NPRM_FINAL.pdf

To see public comments or make your own, go to http://www.regulations.gov and put in search term ‘E9-31216’ or ‘E9-31217’.

I particularly like the public comments at this link.

“Additionally a rushed, not well planned conversion to a new EMR will create the risk of a costly implementation failure with users ultimately rejecting the system.

NMHS believes that the data gathering required for meaningful use will require more resources than it can afford.”