Dr. Christina Morris, commenting as a family physician, said "I am strongly opposed to this rule…as it will serve only to increase tedious workloads by requiring redundant documentation of the need to view critical patient information to perform clinical duties" She expressed concern that the "issue of necessary practitioner access to medical records will only serve as fodder for the already encumbered medical liability system until appropriate tort reform measures are addressed."
Here is a sampling of the other comments posted on regulations.gov:
American Health Information Management Association represents 61,000 health information management professionals. Dan Rode, vice president of policy and government relations, wrote "Although we strongly support the right of individuals to ask questions regarding access to their PHI, we are troubled because such rules go outside of the current scope of HIPAA, even with the HITECH amendments… the transition to electronic health record systems did not contemplate the necessity of tracking this level of access or take into consideration the potential administrative costs, and thus, will cause significant burden for covered entities and their EHR vendors."
"AHIMA queried our HIM professionals on how they currently handle individuals' concerns about who has accessed their electronic health records. The HIM professionals indicated that they have been able to respond to the queries and satisfy the individuals without providing the details proposed in the access report...AHIMA suggests it would make more sense to require covered entities and business associates to respond to these requests on an ad hoc basis rather than require significant systems and process changes that will raise the cost of healthcare for what appears to be a very limited number of requests."