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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NEW MENU: “>40% of all scans and tests whose result is an image ordered are incorporated into or accessible in EHR”

We support access to imaging results and images through the EHR. We request clarification between imaging results (e.g. narrative report) vs. images. Imaging results (narrative) should be accessible within the EHR. Since bi-directional electronic order communication between ambulatory EHRs and imaging centers is not prevalent today, results may need to be delivered via a messaging standard (such as Direct) which may require ambulatory staff to manually match results with the order until standards for bi-directional order communication for radiology are widely adopted.

Image access within the EHR should be differentiated from incorporating images within an EHR, as the latter requires significantly more network bandwidth and storage capabilities.
Today many EHRs provide links to images accessible within an EHR, which then launches a web-based PACS viewer, providing those with credentials the ability to view images. We believe that this is important functionality to enable within EHRs. However, we believe that currently EHRs do not track whether a PACS link is “available” or “clicked on” as this interaction happens largely with the web-based PACS application. Visually, the web PACS application may appear to be within the EHR, but it is often “within the viewing frame” of the EHR application, but actually running a 3rd party application. We believe that there are likely barriers to EHRs collecting information about the availability of 3rd party data accessible via a web link within the EHR to sufficiently meet this requirement.

Today, digital imaging/PACS for radiology is not a requirement. Many practices may have imaging equipment within their office, medical office building/complex, or nearby vicinity that is not PACS enabled. Patients may be steered to centers that are not convenient.
Comment Period Closed
May 7 2012, at 11:59 PM ET
ID: HHS-OS-2012-0004-0372
Tracking Number: 81007283

Document Information

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

Submitter Name: Anita Samarth
Organization Name: Clinovations