In a letter dated April 18, CHIME outlined its suggestions to Farzad Mostashari, national coordinator for Health Information Technology at the Office of the National Coordinator for Health Information Technology (ONC).
Currently, there are no percentage targets to meet before moving to Stage 2. By establishing "a reasonable percentage" for EP and EH attainment of Meaningful Use objectives, CHIME said the measure 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."
The letter was sent in response to ONC's request for comments regarding the Federal Health IT Strategic Plan: 2011–2015. CHIME raised other concerns and made several additional recommendations which include:
-- ONC needs to further define how consent management of patient information 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 consent process also must support exchange with personal health records (PHRs) so that information between patients and their providers is accurate, secure, and furthers the goal of improved care.
-- CHIME is urging ONC to establish standards for a national privacy regulatory environment that would apply to all health information exchanges. The organization said this is yet another example of how the current HIPAA preemption policy creates problems by essentially allowing geographic variation in privacy rules, which complicates compliance and makes it more costly.
-- CHIME questions the wisdom of granting patients instant access to all health information, like lab results, which will likely require explanation. This kind of access could be counterproductive, and even dangerous, without the proper context and clarification from health professionals.
In the meantime, ONC has extended its deadline for public comment on the Federal Health IT Strategic Plan: 2011–2015 to May 6.
The plan, which was unveiled last month, describes how ONC will work collaboratively with its federal partners and the private sector to foster the adoption of health information technology.
Building on meaningful use, the plan also addresses how ONC and its federal partners will increase protections to ensure that electronic health information is kept private and secure, empower individuals with access to their electronic health information, and enhance the ability to study care delivery and payment systems.