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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The Missouri State Chiropractors Association discussed this issue at its last MSCA Board of Directors meeting, and we feel this will place an undue burden on the chiropractors and other smaller medical providers who do not have a digital system. Many in our chiropractic profession do not have the capacity to transmit digital images. Standard plain film radiographs are still an acceptable medical standard. By requiring digital imaging, you are asking us to abandon a standard, medically acceptable technology for a different technology. This is not a reasonable request. Electronic Medical Records will demonstrate that an x-ray study has been performed, and a copy of the report will be in the records.

We, as a profession, are concerned with patient safety issues and medical costs which are both issues with redundant and duplicative imaging. In most cases, we are not dealing with emergency situations where time is of the essence, requiring records to be immediately accessible. It is a standard within our profession to take images that are medically necessary; and, if radiographs are available, we do not repeat them unnecessarily. Since most of our cases are not emergency situations that require immediate accessibility, it allows us time to request the images or reports.

The additional cost for our offices to be able to take digital x-rays and/or scan them into an acceptable medically diagnostic format is burdensome, unnecessary and unreasonable. This additional cost will also, in turn, result in an increased cost to the patient.



MSCA Response to Federal RIN 0991-AB82

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Comment Period Closed
May 7 2012, at 11:59 PM ET
ID: HHS-OS-2012-0004-0112
Tracking Number: 8100399c

Document Information

Date Posted: May 2, 2012
RIN: 0991-AB82
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Submitter Information

Submitter Name: Paul Foster, DC
Organization Name: Missouri State Chiropractors Association