Again, I'm not sure, at this point in my studies, that I have adequate grasp of this subject to be entitled to ramble on about it... but hey, I did stay at a Holiday Inn Express last night. =)
... Seriously, though, given that this is the "Silly Season" of politics, the letter struck me as more like political saber-rattling than a concise and specific critique. Why, specifically, do they opine that the current CPT "does not meet the needs of hospital providers"? They do not say. In what ways, specifically, should CMS change it? They do not say. Have they any clue how massive a task that would be, or how expensive, or who should pay for it? They do not say (though I bet I can guess who they think should pay for it).
Also, it would be useful to see statistics quantifying the problem with lack of intraoperability. How many EHRs in place now are intraoperable, and how many are not? Does anyone even know?
...The doctors' side of the increased-billing debate (they claim that with EHRs they are now able to better/more accurately capture certain charges than they were before) is not being considered...Shouldn't it be at least discussed?
In a similar vein, if you read doctors' blogs from time to time you get a sense that the real and hugely frustrating problem, at least from their perspective, is the software vendors.. the companies that design and very aggressively market the EHR products to doctors and facliities. It seems that often these software packages are sold with a lot of less-than-reality-based promises... then, once the money is spent and they're stuck with it, the healthcare providers on the front lines find that they cannot customize the software, such as templates, for their own needs, making the EHR clunky, time-consuming, or even useless.
That problem experienced by many docs, plus the intraoperability issue--if it is one--would require that the vendors, collectively, need to have their feet held to the fire, too. Not just the providers; after all, it's we taxpayers plus the providers who are paying for this EHR mandate and having to deal with its consequences-- but follow the money. It's the software vendors who are profiting, and hugely, from this EHR mandate. The committee doesn't seem to be paying much attention to that, or mentioning that the vendors might bear part of the responsibility for any problems. Hmmm...
That said, I do, however, agree that intraoperability standards should have been prepared and distributed beforehand. Really, it seems almost insane that this was not done. It doesn't take a degree in computer programming to see that the absence of intraoperability standards-which I assume means, lateral compatibility, i.e., that a provider at one facility with EHR A would be able to read a patient's chart at another facility with EHR B--poses a serious problem that does need to be addressed, and with a quickness.
I think you made some brilliant points! Other than the fact that switching over to these systems costs tons of money, the most important obstacle is compatibility. There is not one program that is powerful enough or has enough people buying into it so that we can reasonably expect to have these programs communicate with each other.