A counter to that would be that organizations need time to plan for upgrades, technology fixes, and optimizing technology. In a 365-day reporting period, you don’t get that flexibility, do you?
We did say in the letter that there are flexibilities woven in, in many different ways. I would call low thresholds as an example of flexibility. Lots of people are coming in way above those thresholds. Even though the average is far higher than the thresholds, the minimums are still low. There is also flexibility in the exemptions that say if you don’t meet these criteria, you don’t have to report on it in the first place. There are also hardship exemptions for software upgrades not getting done by vendors. There is a lot of flexibility in the system already. With all of that, we don’t think that a 90-day reporting makes sense.
Another complaint from providers is that the MU program is reliant on EHR systems that have too many usability issues. Is that something you agree with?
Doctors have raised usability issues, and ONC is working with doctors and vendors who are at the table making these recommendations to ONC on how to fix these issues. They testify at the hearings and the results are based on the advice that they are giving. Even with doctors’ and vendors’ own good thinking, there are still usability issues. We are at the beginning of some major improvements in healthcare in the nation, and that’s what Congress wanted with HITECH. When you have systemic change like we have had, what gets developed at the beginning won’t be the same as what you see at the end. There are usability issues, sure—that doesn’t mean we can’t keep moving forward. What happens when it’s the patient who catches the error in the doctor’s record that says “no allergies,” but the patient is actually allergic to Penicillin? The patient just saved a major problem. The online access, as one example, will move us in the right direction. You can’t pause the system—it’s overdue.
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