Loonsk, John. "Comments for the Meaningful Use Commenters: Specificity Matters." Governement Health IT, April 2, 2012.
From the article: "Stage 2 of Meaningful Use has an increasing number of process measures that try to encourage health information exchange between and, by implication, inside of organizations. But asking for information exchange or interoperable systems without highly detailed, implementation guide “cookbooks” for each transaction means that the costs and burden rests with each healthcare provider. As far back as 2005 when HITSP started its work in the first national health IT agenda, there was a consensus assumption that standards-based, implementation-level guidance for health-related transactions was a principal need and goal. Stage I Meaningful Use had almost no implementation level guidance because, according to the Health IT Standards Committee, no guidance was ready. It is not clear there is more, well-tested implementation guidance available now for Stage 2, but fortunately there is still incrementally more in the regulation.
Comments that push back on implementation level guidance, while there are still process measures that demand the transactions occur, put healthcare providers on the hook for costs and effort for making ad hoc transactions happen. When adequate specificity of implementation guidance is present, much of the burden is shifted to the software developers. Instead of provider-funded, ad hoc transactions in each clinical setting, we get closer to having transactions that that can be built once by each vendor and used in many different implementations." Read more
