The  American Medical Association, the American Hospital Association, and numerous other stakeholders are raising concerns that the timelines for adoption of EHR features that must be met in order to meet the proposed HITECH "meaningful use" criteria are unrealistic.  The AHA’s comment letter stated:

"…[R]ational timelines are needed. We recommend a lead time of one year between finalization of the certification criteria and certification of vendor systems. Providers need an additional two years between the time when certified products are available in the market and whenproviders nationwide are expected to implement and begin using them to meet the meaningful use criteria." 

The comment letter signed by the AMA and 96 other medical organizations stated:

We do, however, feel strongly that the Stage1 criteria proposed by CMS for achieving meaningful use of EHRs is too aggressiveand if adopted, will deter many physicians from participating in the Medicare andMedicaid incentive programs. This runs counter to the intent of ARRA, whichclearly indicated that demonstrating meaningful use should progress over time.

They have found receptive ears among some members of Congress.  For instance, Rep. Michael C. Burgess, M.D. (R-TX) has written that CMS’ definition of ‘meaningful use’ of EHR will "hinder hospitals’ adoption of advanced IT."  A group of 37 senators wrote to CMS on March 30 asking for changes in the EHR standards. Rep. Chris Van Hollen (D-Md.) has also been critical of the ‘all or nothing" approach taken by CMS in the proposed rule.  On March 15, Rep. Burgess joined with 248 of his fellow House members to write to CMS asking for changes to its definition of meaningful use. His summary appears here.

We will have to wait and see to what extent CMS will follow the recommendations of these advocacy groups when issuing final "meaningful use" rules later this year.