"Moreover, it virtually REQUIRES electronic medical records because it is too hard to comply with many of the provisions without them."
If a doctor does not use electronic billing then they are exempt from HIPPA....Of course that is virtually impossible nowadays. I agree the whole thing should be scrapped along with E&M coding guidelines....They are just as stupid and unworkable.
I agree about scraping the E&M guidelines not being representative of the "work" that the physician actually does, but please lets find another way to do it.
After all I am a certified coder, and I kind of like having a job.LOL