6. Implementing computerized physician order-entry (CPOE) is a tremendous task, and adoption levels are very low. Implementation of CPOE must be paced according to individual provider needs, and it is unreasonable to require criteria related to CPOE before 2015.

Consumer response: CPOE is a foundational tool necessary to provide the most effective,
appropriate care for patients. Without CPOE, providers can't take advantage of all of the functionalities of an EHR system, such as reminders for follow up care, clinical alerts and decision support. Hospitals would be required to use CPOE for just 10 percent of physician orders in Stage 1.

7. Many of the criteria require significant workflow and system changes to incorporate services that are not reimbursed.

Consumer response: While these kinds of activities may not be paid for explicitly under fee-for-service, the meaningful use incentives act as a financial reward for this kind of patient-centered care. This will translate to the kind of better provider-patient relationships and more patient-centered care that providers and patients both want. We can't successfully implement further payment reforms without an underlying healthcare IT infrastructure to connect our fragmented system and report on how providers are performing.

8. Providing patients with access to their health information is too much of an added burden on providers.

Consumer response: If patient health information is available electronically to a provider, it can and should be made available electronically to patients. This is not a burden when designed well, such as when information is accompanied by education and resource materials that help consumers understand and use their own information effectively.

9. Collecting structured data on race, ethnicity, preferred language and gender (RELG) is too burdensome for providers.

Consumer response: We need to collect better information about the demographics of patient populations. We hope that in the final rule and succeeding definitions CMS will go further and require the analysis and use of this information to reduce and ultimately eliminate disparities.

10. Forcing providers to implement health IT too rapidly will ultimately harm patients.

Consumer Response: The meaningful use incentive program is voluntary. Patients are already being harmed every day due to the absence of information necessary to provide consistent, high quality care. Patient safety is a top priority for all stakeholders, and work is underway to monitor health IT-related safety issues.

Click here to submit your own comments to the ONC.