Comment on FR Doc # 2012-04430

This is a Comment on the Department of Health and Human Services (HHS) Proposed Rule: Health Information Technology; Implementation Specifications, and Certification Criteria: Electronic Health Record Technology, 2014 Edition

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CPOE: Believe that this Stage 2 requirement would make more sense to either just up the % requirement for the medications OR make the 30% stay the same with the additional of the lab or radiology order. Physicians are highly stressed with these requirement for the EH/EP and think a lesser percentage would help them move forward easier.

Clinical Quality Measures: This should be more closely aligned with quality metrics already being reported with other CMS programs (i.e. ACOs, PCMHs, PQRs)

Patient reminders: Need exclusion for patients who choose NOT to receive reminders and it should be a current/active patient. This should also be a requirement ONLY for providers who have continual care responsibilities for a patient.

Electronic Copy of Health Information: Any electronic copies should be worded to say "At patient request". Should not have to auto supply electronic copy unless patient wants it. This should apply to everything - Clinical summaries, Discharge instructions etc)

Hospital Portal: This percentage is too high for a new measure. Also need clarification for relevant information.

Patient-Provider Secure Messaging: This is a huge burden for providers. Patients need to be able to opt out. Text messaging is not secure and should not be allowed except maybe for appointment confirmation or non result related things.

List of Care Team Members: Seems almost like a privacy violation for employees. This should ONLY be upon patient request, not just a % of all
Comment Period Closed
May 7 2012, at 11:59 PM ET
ID: HHS-OS-2012-0004-0029
Tracking Number: 80fe3c22

Document Information

Date Posted: Apr 9, 2012
RIN: 0991-AB82
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Submitter Information

Submitter Name: Sandra DePlonty
Organization Name: War Memorial Hospital