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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Comment

Dear Mr. Posnack:
On behalf of the membership of the Pharmacy e-Health Information Technology Collaborative (Collaborative), we are pleased respond to the Health Information Technology: Standards, Implementation Specifications, and Certification for Electronic Health Record Technology, 2014 Edition; Revisions to the Permanent Certification Program for Health Information Technology Notice of Proposed Rulemaking published in the Federal Register on March 7, 2012.

The Collaborative submits its comments in the attached document. The Collaborative is supportive of the proposed revisions to the permanent Certification Program for Health Information Technology as it applies to the objectives of the EHR Incentive Program in Meaningful Use—Stage 2; however, we are concerned that some of the proposed measures will become unfunded mandates (these areas are noted throughout our attached comments). Pharmacists are ineligible for EHR incentives, though they will need to exchange information with EHR systems to connect to and ensure needed bidirectional communication with EPs. As implementation of Stage 2 moves forward; especially with regard to the certification criteria for EHR technology, it should not create additional or financial burdens on pharmacists, such as becoming an unfunded mandate.

The Collaborative was founded by nine pharmacy professional associations representing over 250,000 members and includes six associate members from other pharmacy related organizations. For additional information, visit www.pharmacyhit.org

On behalf of the Pharmacy e-HIT Collaborative, thank you again for the opportunity to comment on the Health Information Technology Standards Implementation, and Certification Criteria for Electronic Health Record Technology, 2014 Edition; Revisions to the Permanent Certification Program for Health Information Technology proposed rule. For more information, contact Shelly Spiro, Director, Pharmacy e-HIT Collaborative at shelly@pharmacyhit.org.

Attachments

 (2)

5-4-12 EHR Certification Public Comments

View Attachment:

5-4-12 FINAL EHR Certification Comment Letter _1_

View Attachment:

 
 
Comment Period Closed
May 7 2012, at 11:59 PM ET
ID: HHS-OS-2012-0004-0228
Tracking Number: 81006368

Document Information

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

Organization Name: Pharmacy e-HIT Collaborative