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 Society for Participatory Medicine applauds the work done to date in focusing on patient engagement in the proposed Stage 2 Meaningful Use regulations and the proposed Health IT Standards regulations. It is our hope that the final requirements will be even stronger and more focused in this regard than the current drafts.

As set forth in greater detail in the attached letter, we have a number of comments that we believe will improve the regulations and their use as a lever to improve patient experience, patient engagement, patient care and, ultimately, patient outcomes.

We would like to highlight two in particular:

We favor improving the likelihood that patients will access their data by allowing for some automation of the process of accessing and downloading patient data, using existing technologies that protect patient privacy and security.

We also favor immediate patient access to information in the patient’s electronic health record - unless the patient has elected otherwise.

The overarching principle with respect to patient access to electronic health record data running through the entire meaningful use regulation and the health IT standards regulation should be:

"Nothing about me without me."

The Society for Participatory Medicine has individual and institutional members nationwide and has a governing board comprised of both clinicians and patients. It was founded to study and promote participatory medicine, which we define as being centered on networked patients shifting from being mere passengers to responsible drivers of their health, and providers who encourage and value them as full partners. For further background on the Society and its activities, we invite you to see the Society’s website (, its online journal, The Journal of Participatory Medicine ( and its blog, (



S4PM comment letter to ONC on Stage 2 MU regs 050412

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Comment Period Closed
May 7 2012, at 11:59 PM ET
ID: HHS-OS-2012-0004-0196
Tracking Number: 8100544c

Document Information

Date Posted: May 7, 2012
RIN: 0991-AB82
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Submitter Information

Submitter Name: David Harlow
Organization Name: Society for Participatory Medicine