Two quick observations are below; look for a separate post in the coming days on how these new rules affect document management, particularly Release of Information.
- Across the board, the final rules are a lot less ambitious than the preliminary ones. This is mostly a good outcome because we still don't know the behavior these rules will motivate. More* on this at the end of the post.
- The preliminary rules were written with an assumption that medical records will be mostly electronic by 2015. Several studies suggest this goal is not realistic, so it will be interesting to hear whether these rules will indeed prevail or whether there would be further changes down the road. A Bass Diffusion model applied to physician EMR systems by Prof. Eric W. Ford and others claims true adoption will take a decade longer than anticipated. And that's the optimistic scenario!
I look forward to hearing your thoughts in the comments section below.
*Why less ambitious rules may be a good thing: Rob Lamberts at The Health Care Blog draws an analogy between Meaningful Use rules and those in No Child Left Behind--another well intentioned legislation that introduced undesirable behavior on the part of the actors (the teachers). One would rather have rules that are realistic than those that are so strict everyone has to find workarounds.