Comment on FR Doc # 2012-04430

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On behalf of the 3,000 cardiologists in private practice and within integrated organizations across the country that we represent, the Cardiology Advocacy Alliance (CAA) submits the following comments on the proposed rule for the Health Information Technology; Implementation Specifications, and Certification Criteria: Electronic Health Record Technology, 2014 Edition. CAA’s mission is to support the sustainability of the cardiovascular professional regardless of practice setting. CAA member practices devote themselves to continuous quality improvement and use benchmarking data and other tools to ensure that they are offering the highest quality care to their patients.

As we made clear in our comments on the first meaningful use proposed rule, CAA fully supports the need for a nationwide health information infrastructure and the use of Electronic Health Records (EHRs) to increase patient safety, improve efficiency and promote access to patient medical information across the health care spectrum. However, CAA is uncertain for our members’ success to achieve Stage Two as we believe that the Agency greatly overestimates the number of medical professionals that have or preparing to deploy EHRs and the consistency of EHR use across specialties, sites of service, geography and venders.

Although the EHR incentive program is focused more for the primary care provider than the specialist, cardiovascular disease is our nation’s number one killer. We hope that ONC appreciates the role of the specialist as this rule is finalized and finds opportunities to bolster collaboration between primary care providers and cardiac care professionals. Please see our full comments attached to the companion meaningful use rule which accompanied this regulation in the Federal Register.

Thank you for this opportunity to comment. Please contact Jen Searfoss, Executive Director, at 202-505-2221 or for any assistance.




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Comment Period Closed
May 7 2012, at 11:59 PM ET
ID: HHS-OS-2012-0004-0369
Tracking Number: 8100727c

Document Information

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

Submitter Name: Dan Caldwell
Organization Name: Cardiology Advocacy Alliance