Thus far, I've briefly skimmed comments from:
- Chillmark Research (I love the editorial comic at the top of this one)
- eHealth Initiative
- EHR Association
- HIT Policy Committee
There's some remarkable agreement among all of these comments:
1. Quality Measures need to be streamlined.
2. An incremental approach to incentives should be used.
3. The bar is set too high in some places (e.g., CPOE).
Of course, my survey is anything but scientific.
If you care to, you can read all the feedback on the proposed rule for incentives (use keyword: CMS-2009-0117) and the interim final rule on standards and certification (use keywork: HHS-OS-2010-0001) at http://www.regulations.gov/.
Next comes the interminable silence while CMS and ONC cycle through the thousands of pages of these comments and we see how they decide to take these comments into account later this spring.