While there have been signs in recent weeks that policymakers are willing to “soften” some of the recently proposed “Meaningful Use” standards, some stakeholders continue to advocate for a more comprehensive overhaul of the proposal, including a reassessment of the potential cost to providers of implementing EHRs.

 The latest pushback came at the end of last week, when College of Healthcare Information Management Executives (CHIME) filed comments with the Centers for Medicare & Medicaid Services that voiced “critical concerns” over the proposed regulations.

Given that CHIME speaks for “1,400 members representing chief information officers and other top information technology executives at many of the nation's largest hospitals”, it seems reasonable to assume their concerns are shared by many of their peers across the country.

In both a full letter (PDF) and an Executive Summary (PDF) released on Friday, CHIME offered several criticisms of the proposal, as well as a number of suggestions for how policymakers might increase the chances for successful implementation of the standards in the years ahead.

One recurring theme which caught our eye was a desire to ease off on some of the timelines associated with implementation of the standards.

For example, the organization states that “the 23 proposed objectives defining meaningful use of an EHR system in 2011 set a high bar for adoption that is unachievable by the vast majority of U.S. hospitals within this time”, and it suggested that policymakers “give providers until 2017 to adequately achieve all of the components for EHR implementation.”

But perhaps the most intriguing of the organization’s criticisms was that “impact analyses in the rule seriously underestimate the total cost of ownership for these
systems, and overstate the amount of incentive payments in aggregate that will be paid if the proposed rules are implemented.”

Presumably, this comment reflects what CHIME members have concluded after doing the numbers for their own organizations. The group recommends “that EHR acquisition and ongoing expenses be reassessed to help individuals and organizations who will need to prepare budgets not only for implementation, but for ongoing operations.”

That’s a reasonable suggestion, but if it’s true that policymakers have underestimated the cost of EHR implementation and maintenance to providers, that’s likely to have an impact on the number of providers who are willing or able to make the necessary investment.

At the very least, given the public’s investment in this process through the HITECH incentive program, policymakers should be sure they have a solid grasp on the provider costs so that they can project how much EHR progress the public’s investment is going to buy.