Pulling Forward the Benefits of HIT - Federal Comments

The government is asking for "the public's" input on how to "Pull Forward the Benefits of HIT". I'm a bit confused as to how much they want input on that general topic vs. just how Standards play into it; as well as whether to just post a comment or do something elsewhere... so, I just posted a comment and we'll see if this changes their mind completely :)

Comment Posted to their site 11/03/09
My perspective comes as a practicing PCP (Internist) who has used an EMR since 2002, as Medical Director of Clinical Information Systems for a large primary care group, as a past Medical Director for an EMR company, and active consultant in the EMR space.

I’m all for using EMRs meaningfully, and second, I’m all for rewarding physicians! However, I believe (as many do) that our current crop of EMRs are far from perfect and I have to question whether we could spend that $36 billion a better way than by rewarding mediocre vendors whose products are poorly adopted and poorly used (see the National Research Council’s recent report via this short press release, and this full PDF of the report: http://books.nap.edu/openbook.php?record_id=12572&page=R1). Rather, for a fraction of that money, perhaps we should consider creating a national EMR framework upon which vendors could build their applications (yes- sort of like the iPhone). This then solves interoperability immediately, and lets the vendor compete on applications and user interfaces rather than on all wasting time/money trying to replicate databases which limit their ability and creativity in building what we really need. More thoughts on this topic: http://www.modernhealthcare.com/apps/pbcs.dll/article?AID=/20090430/REG/304309994/1029&nocache=1#

However, if we do keep the current definitions of Meaningful Use, then my three main talking points would be:
1. E-Prescribing: make this definition broad enough to reward providers who use their EMR to create and print out scripts, don’t limit to just electronic transmission to the pharmacies, as that is not yet a perfect science.
2. Interoperability: reward based on ability to share data in a group or with a hospital, but don’t require regional or national sharing at this point, that is way beyond the means of most providers and vendors.
3. Data reporting: reward based on producing the reports, whether from the EMR, an EDW (Enterprise Data Warehouse) or similar. Most EMRs are bad at report writing, and other tools are needed.
More details on all three at: http://www.histalkpractice.com/2009/08/25/drlyles-meaningful-discussion-about-meaningful-use-82609/