I can certainly see how the cloud only satisfies a few requirements; much of the security assessment deals with office organization and clerical issues, quite a pain. Not sure how it adds a new layer of security requirements, though.
I just had some folks from the local health department (which has a program to help MD's attain MU) come to the office to walk through the security assessment. When we got to the EMR implementation and I told them I was going to the cloud, they said that makes the assessment easier, since you no longer have to deal with local network, hardware and server security issues.
Michael
NY