Specifically, CHIME asks the Office of the National Coordinator for Health Information Technology 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 that ONC should act to ensure that laws keeping health information private are more uniform from state to state.
“CHIME urges ONC to establish standards for a national privacy regulatory environment that would apply to all health information exchange,” the comment letter said. “We consider this yet another example of how the current HIPAA pre-emption policy creates problems by essentially allowing geographic variation in privacy rules, which complicates compliance and makes it more costly.”
CHIME further urges the Office for Civil Rights (OCR) to re-examine its stance with respect to federal pre-emption “in a way that facilitates, not hinders, health information exchange across jurisdictional boundaries.”
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.
“However…caution should be exercised when expecting EHRs to do too much, too fast – such as accommodate multiple languages and disabilities,” CHIME noted.
“Through its Strategic Plan, ONC has laid out its vision for an e-enabled healthcare system,” said Sharon Canner, senior director of Advocacy Programs for CHIME. “We are encouraged to see continued focus and resources being placed on EHR adoption and health information exchange, but we also know many challenges lie ahead for hospital CIOs. We look forward to working with ONC as it strives to meet its ambitious goals in improving health and healthcare through the use of information and technology.”
To read CHIME’s full comments, please go to: http://cio-chime.org/advocacy/CHIME_ONC_StrategicPlanCommentsLettertoMostashariApril2011.pdf
Or view them on ONC’s Health IT Buzz Blog, visit: http://www.healthit.gov/buzz-blog/from-the-onc-desk/hit-strat-plan/#comment-24171
