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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Proposed 2014 Edition EHR Certification Criteria

New Certification Criteria
a.Ambulatory and Inpatient Setting
§ 170.314(a)(9) - Electronic notes
MU Objective
Record electronic notes in patient records. (Not proposed by CMS)
2014 Edition EHR Certification Criterion
Electronic notes. Enable a user to electronically record, access, and search electronic notes.
Preamble FR Citation: 77 FR 13838Specific questions in preamble? No
Public Comment Field:
Major Concern
As detailed in our introduction, we are significantly concerned that the scope of the certification program is endangering some of the goals of Meaningful Use by introducing unnecessary overhead and burden.
As electronic notes are not proposed as a Meaningful Use objective with the rationale that electronic notes are already in common use, we do not think certification on this criterion is necessary, and suggest removal. Introducing unnecessary certification criteria creates expense for ONC, certifying bodies, and EHR developers, and does not provide significant value to the marketplace.
Keep consistent with CMS and remove this criterion from the Final Rule.
Secondary Recommendation
If this criterion is retained in the Final Rule, we suggest that the criterion should be an optional certification for the same reasons, and we make the following suggestions:

We agree with your assessment that having notes be searchable provides increased value over notes that are part of a scan or other formats that are not able to be searched. Our experience shows that note search capabilities is complex with potential for innovation in how information is found and displayed. Prioritization of such capabilities is best left to the marketplace. Search is not essential to meet the not-proposed objective drafted by CMS. Focus certification on the minimum floor set of capabilities required to complete meaningful use objectives. Therefore, we suggest that search capabilities be excluded from cert



University of Miami ONC Stage 2 Draft Feedback

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Comment Period Closed
May 7 2012, at 11:59 PM ET
ID: HHS-OS-2012-0004-0241
Tracking Number: 81006676

Document Information

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

Submitter Name: Rosa Blanco-Herrera
Organization Name: University of Miami Health System