Despite the noticeably more relaxed verbiage of the new "meaningful use" critera matrix, many believe too much is still required for stimulus eligibility. Indeed, a whopping 22 requirements must still be met by 2011. Can it be accomplished over the next 4-5 years, or are providers still being asked to do too much?

The new definition is more relaxed when it comes to CPOE (only 10% of orders must be entered), and the timeline overall. The new "adoption year" scheme allows implementations that take place between 2013-2015 to be graded on the same requirements scale as those in 2011-2013, giving leverage to those who implement later in the game.

Meanwhile, the HIT Policy Committee has notably expanded some requirements, including mandated audits and, for example, recommending CMS "withhold meaningful use payment for any entity until any confirmed HIPAA privacy or security violation has been resolved."

Rick Weinhaus of The Healthcare Blog weighs in:

... the situation is not nearly as bleak as it seems. EHR technology can begin to improve patient care right away if we adopt the right model. There is no reason that it should take 2 or more years for physicians to train to use EHR technology. With well-designed, user-friendly EHR software, physicians can be up and running with core functions in 2-3 weeks, not 2-3 years.

We need to remember that Congress and the Obama administration have entrusted the national HIT Policy Committee, not CCHIT, with the mandate to shape our new HITECH policies. The national HIT Policy Committee needs to keep EHR certification rules simple and focused on standards for data, interoperability, and privacy. Keeping certification rules simple will allow physicians and hospitals to select well-designed, user-friendly EHR software that can be used meaningfully from the start.

While the criteria have been simplified, and some providers are assuredly ahead of the game, has the HIT Policy Committee gone far enough? The newly released definition still requires quite a bit, even by 2013, to start receiving stimulus funds, and significant penalties later in the game.