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CHIME to ONC: Be Cautious on Aspects of Federal Health IT Strategic Plan

April 18, 2011

The College of Healthcare Information Management Executives (CHIME) urges caution and should not expect electronic health records to do too much, too fast in submitted comments on the proposed Federal Health IT Strategic Plan. CHIME supports the Strategic Plan’s goals, but also seeks refinements that will increase the likelihood for – effective and widespread adoption of information technology by healthcare providers.

Specifically, CHIME asks the Office of the National Coordinator for Health Information Technology (ONC) to provide standardized approaches and to allow sufficient time to encourage the adoption of electronic health records systems and supporting technologies by providers.

“The Strategic Plan is important for us to understand how the government perceives the next steps in achieving meaningful use of health IT,” said Gretchen Tegethoff, CIO of George Washington University Hospital and vice chair of CHIME’s Advocacy Leadership Team. “This plan offers hospital CIOs a chance to gauge their progress against future goals and helps us see how implementations we’re making today will fit into larger plans down the road.”

“Our comments touch on a number of issues and challenges we’re facing while working with ONC to advance and standardize the adoption of health information technology and health information exchange,” said Indranil “Neal” Ganguly, vice president and CIO of CentraState Healthcare System, Freehold, N.J., and a member of CHIME’s Policy Steering Committee. “From data safety and integrity to continued evolution in EHR usability, hospital CIOs are at the forefront of this transformation, and we are pleased to offer guidance on how ONC can move forward.”

The professional organization’s comments highlighted the need to ensure confidence and trust in health IT, particularly in facilitating the exchange of patient information to support care delivery. CHIME recognizes the need for patient confidentiality and privacy protections, but the comments detail the need to balance those concerns with the need to exchange health information when necessary.

“Several of the objectives listed throughout the Plan foresee the fluid exchange of the right information, at the right time, for the health and safety of patients,” the CHIME comment letter said. “To make sure this information is shared responsibly, ONC needs to further define how consent management should be handled, and it must address the responsibility of patients, physicians, hospitals and insurers on how consent will be stored and transmitted through health information exchanges (HIEs).”

The process of gaining consent from patients for the exchange of their health information also must support the exchange of information derived from patients’ personal health records (PHRs), CHIME said. That is important to ensure that “information between patients and their providers – no matter the source – is accurate, secure and furthers the goal of improved care.”

CHIME also urged ONC to act to ensure that laws keeping health information private are more uniform from state to state.

Ann Arbor, Mich.-based CHIME also supports ONC’s approach in quantifying hospital and physician performance in achieving meaningful use objectives. It reiterated its request that Stage 2 Meaningful Use Objectives not be implemented before 30 percent of eligible hospitals and eligible professionals have achieved Stage 1 objectives.

“We believe that this approach would strike the right balance between the desire to push EHR adoption and MU as quickly as possible and the recognition that unreasonable expectations could end up discouraging EHR adoption if providers conclude that it will be essentially impossible for them to qualify for incentives.”

CHIME also asks for more alignment among HHS regulations affecting the timeliness of patient access to information. It notes that the timeliness standard under the HIPAA provisions “is significantly different from that under the electronic health record meaningful use regulations recently adopted by HHS (30 days for information maintained onsite vs. three business days).”

Finally, CHIME supports efforts to study the usability of EHRs, clinical decision support, health information exchange and telehealth tools. “It will be important to keep healthcare CIOs engaged about how their constituent physicians, nurses and other clinicians are interfacing with EHRs and re-engineering their work processes.

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