Electronic Health Records (EHR) Workgroup: All WG Recommendations made to the American Health Information Community.

As of April 2008, the EHR workgroup formally submitted 38 recommendations to the full AHIC. 32 were accepted, 6 were tabled and none were rejected.

All EHR Workgroup recommendations were made with the focus of advancing the EHR workgroup’s charges:

Broad Charge: Make recommendations to the Community on ways to achieve widespread adoption of certified EHRs, minimizing gaps in adoption among providers.

Specific Charge: Make recommendations to the Community so that within one year, standardized, widely available, and secure solutions for accessing current and historical laboratory results and interpretations are deployed for clinical care by authorized parties.

May 2006 Recommendations

Provider & Patient-Centric Models

  1. Recommendation 1.0: The U.S. Department of Health and Human Services (HHS) should take immediate steps to facilitate the adoption and use of endorsed standards and incentives needed for interoperability of lab results within the current provider-centric environment. The Office of the National Coordinator for Health Information Technology (ONC) shall work with multiple stakeholders to develop a detailed work plan to achieve patient-centric information flow of laboratory data by March 31, 2007. AHIC decision: Accepted

Standards

  1. Recommendation 2.0: HITSP should identify and endorse vocabulary, messaging, and implementation standards for reporting the most commonly used laboratory test results by September of 2006, so as to be included in the CCHIT interoperability criteria for March 2007 certification. HITSP should consider CLIA and HIPAA regulatory requirements as appropriate. AHIC decision: Accepted

  1. Recommendation 2.1: Federal health care delivery systems (those which provide direct patient care) should develop a plan to adopt the HITSP-endorsed standards for laboratory data interoperability by December 31, 2006. AHIC decision: Accepted

  1. Recommendation 2.2: Federal Agencies and Departments with health lines of business should include/incentivize the use of HITSP-approved standards in their contracting vehicles where applicable. AHIC decision: Accepted

CLIA/ HIPAA Options

  1. Recommendation 3.0: By September 30, 2006, ONC should review the possible models for the exchange of both current and historical lab information and determine which would require CLIA/HIPAA guidance, regulatory change, and/or statute change. AHIC decision: Accepted

  1. Recommendation 3.1: Based of the findings from Recommendation 3.0, by December 31, 2006, ONC should engage the National Governors Association and other State-based organizations to resolve variations in “authorized persons” under the various State statutes, regulations, policies, and practices as a resource for clinical laboratories seeking to define access rights to electronic laboratory data. AHIC decision: Accepted

Privacy and Security

  1. Recommendation 4.0: The Community should create a consumer empowerment subgroup comprised of privacy, security, clinical, and technology experts from each Community Workgroup. The subgroup should frame the privacy and security policy issues relevant to all the Community charges and solicit broad public input and testimony to identify viable options or processes to address these issues that are agreeable to all key stakeholders. The recommendations developed should establish an initial policy framework and address issues including but not limited to:

Methods of patient identification

Methods of authentication

Mechanisms to ensure data integrity

Methods for controlling access to personal health information

Policies for breaches of personal health information confidentiality

Guidelines and processes to determine appropriate secondary uses of data

A scope of work for a long-term independent advisory body on privacy and

security policies. AHIC decision: Accepted

Advancing Adoption

  1. Recommendation 5.0: HHS, in collaboration with all key stakeholders, should both assess the value proposition and develop the business case for current and historical laboratory results data sharing across all adoption models, considering the unique needs and alignment of incentives for all stakeholders. AHIC decision: Tabled

Assessment, Monitoring, and Research

  1. Recommendation 6.0: By March 31, 2007, AHRQ, in collaboration with the Centers for Disease Control and Prevention (CDC) and the Centers for Medicare & Medicaid Services (CMS), should develop a proposed study methodology to measure the extent and effectiveness of the adoption of the first stage of HITSP standards, as well as the adoption and utilization of aggregated patient-centric data as they become available. AHIC decision: Tabled

  1. Recommendation 6.1: By December 31, 2007, AHRQ, in collaboration with the CDC and CMS, should research best practices in the implementation and utilization of patient-centric laboratory data stores and how to implement this knowledge. AHIC decision: Tabled

August 2006 Recommendations

Emergency Responder Use Case Recommendation

  1. Recommendation 1.0: Under the leadership of the Office of the National Coordinator for Health Information Technology, an emergency responder use case should be developed and prioritized for the attention of the Health Information Technology Standards Panel and the other ONC lead initiatives. The use case should describe the role that an emergency responder electronic health record will provide, comprising, at a minimum, demographic, medication, allergy and problem list information that can be used to support emergency and routine health care activities. The use case should leverage the work in related activities from the AHIC EHR Working Group and elsewhere. In order to meet the needs of a variety of follow-up activities, this use case should be available in October of 2006. AHIC decision: Accepted

April 2007 Recommendations

Business Case Alignment

  1. Recommendation 1.0: As the Federal Government develops language in its contracts with health plans and insurers to support the widespread adoption of HITSP interoperability standards, this language should foster the use of Pay for Performance programs for physicians that include structural measures to incent the adoption and effective utilization of certified EHRs. This emphasis on structural measures may be limited to a specific time frame with the ultimate goal of using process and outcome measures to assess performance. AHIC decision: Tabled

  1. Recommendation 1.1: These pay for performance programs should use reliable, standardized and validated tools which are currently available to assess structural measures as defined by the Medicare Payment Advisory Commission (MedPAC), such as the NCQA’s Physician’s Practice Connections or CMS’ publicly available Office System Survey. This emphasis on structural measures may be limited to a specific time frame with the ultimate goal of using process and outcome measures to assess performance. AHIC decision: Tabled

Workflow and Culture

  1. Recommendation 2.0: HHS should provide continued support to DOQ-IT U for new module development; upgrades; maintenance; and CME credit management beyond the 8th SOW funded by CMS. The program should be supported by a learning management system that is user friendly, has search functionality, and provides links to other key sites. AHIC decision: Accepted

Medical-Legal Concerns

  1. Recommendation 3.0: HHS should work with the CCHIT to obtain medico-legal counsel to assure that its functional criteria include documentation, security, and other approaches that will mitigate malpractice risk. AHIC decision: Accepted

  1. Recommendation 3.1: HHS should meet with malpractice insurers throughout the country to encourage premium reductions for those physicians who have adopted certified EHRs. AHIC decision: Accepted

Overarching Recommendation

  1. Recommendation 4.0: HHS should develop a schedule for implementing differential reimbursement to Medicare physicians for use or non-use of EHRs. While we would defer to Departmental expertise, we note that this might be achieved by paying full Medicare rates and market-basket updates (and possibly an “EHR premium”) to physicians using certified EHRs, while physicians using paper-based records are paid at discounted rates achieved by non-qualification for full market basket updates or other measures. AHIC decision: Tabled

June 2007 Recommendations

Revised Business Case Alignment Recommendations (1.0 & 1.1) from April 2007

AHIC

  1. Recommendation 1.0: As the Federal Government develops language in its contracts with health plans and insurers to support the widespread adoption of HITSP interoperability standards, this language should foster, but not mandate, the use of financial incentives or Pay-for-Use programs to incent the adoption and effective utilization of CCHIT certified EHRs. Structural measures should be included in these programs, which may be limited to a specific time frame with the ultimate goal of using process and outcome measures to assess performance. AHIC decision: Accepted

  1. Recommendation 1.1: These Pay-for -Use programs should use reliable, standardized and validated tools which are currently available to assess structural measures: for example, the NCQA’s Physician’s Practice Connections or CMS’ publicly available Office System Survey. When the National Quality Forum endorses a set of structural measures, these should be employed by these programs. AHIC decision: Accepted

Business Case Alignment

  1. Recommendation 1.2: HHS should evaluate Pay-for-Use programs with respect to quality, cost and adoption. AHIC decision: Accepted

November 2007 Recommendations

Electronic Prescribing

  1. Recommendation 1.0: The Secretary of Health and Human Services should seek authority from Congress to mandate e-prescribing, pursuant to standards defined by the Medicare Modernization Act (MMA) for e-prescribing 1. This authority should be specific to e-prescribing and not extend to other health care processes. AHIC decision: Accepted

  1. Recommendation 2.0: Prior to exercising authority to mandate e-prescribing, the following requirements should be met: AHIC decision: Accepted

  1. Recommendation 2.1: Flexibility must be maintained, since mandated e-prescribing may not be applicable to all patients, all prescriptions, and all circumstances. AHIC decision: Accepted

  1. Recommendation 2.2: With appropriate Congressional authority, all pharmacies and pharmacy benefit managers must participate in such mandatory e-prescribing. AHIC decision: Accepted

  1. Recommendation 2.3: All prescriptions must be electronically transmissible to the pharmacy of the patient’s choice. AHIC decision: Accepted

  1. Recommendation 2.4: The Certification Commission for Healthcare Information Technology (CCHIT) should develop a certification process for e-prescribing systems that are: (i) interoperable with certified EHRs; (ii) include clinical decision supports to improve safety, efficacy, and efficiency; and (iii) can be extended to integrate with fully functional EHR systems, thus assuring that the e-prescribing investment is a step towards adoption of certified EHRs. AHIC decision: Accepted

  1. Recommendation 2.5: With the appropriate Congressional authority, CMS should develop and institute incentives for both physician/clinician and pharmacy adoption of certified EHRs and/or certified e-prescribing systems early in 2008 before authority to mandate e-prescribing can be granted and exercised. AHIC decision: Accepted

  1. Recommendation 2.6: Continue the successful pilot work undertaken by CMS to make ready important emerging standards, and supplement that work to address sustainability issues such as practice workflow, usability, clinical decision support, and safety surveillance. AHIC decision: Accepted

  1. Recommendation 2.7: Pursuant to Patient Safety legislation of 2005, the Agency for Healthcare Research and Quality (AHRQ) should designate Patient Safety Organizations to monitor and address possible patient issues that may arise as a result of e-prescribing, and patient safety criteria should be included in an e-prescribing certification process. AHIC decision: Accepted

January 2008 Recommendations

Workforce

  1. Recommendation 1.0: HHS should support funding for a collaborative group to research and better quantify discipline-specific workforce deficits (calibrated to different rates of HIT implementation) and to develop an approach for supporting informatics workforce needs. AHIC decision: Accepted

  1. Recommendation 2.0: HHS should work with the Department of Labor to develop occupational classifications for HIT professionals. AHIC decision: Accepted

  1. Recommendation 2.1: HHS should encourage OPM to recognize health informatics professionals in the federal professional series. AHIC decision: Accepted

  1. Recommendation 3.0: HHS should support funding for additional research within specific Federal agencies to create HIT career pathways (including occupational series & job classifications), with particular attention to clinical informatics, research informatics, translational bioinformatics, and public health and population informatics, in support of HIT implementation; improved quality, and clinical effectiveness; systems development; and executive leadership. AHIC decision: Accepted

  1. Recommendation 4.0: HHS should support Federal funding for research in health informatics (including clinical informatics, health information management and IT) which would increase attractiveness of academic careers in HIT and the pool of faculty for HIT curricula in health care disciplines. AHIC decision: Accepted

  1. Recommendation 5.0: HHS should work with the DOE to institute loan forgiveness programs or other incentives to attract necessary health professions trainees to HIT careers in underserved and safety net areas. AHIC decision: Accepted

  1. Recommendation 6.0: Appropriate Federal agencies engaged in HIT should identify and develop informatics competencies for health profession disciplines, and incorporate these in academic programs and mentorship/fellowship programs. AHIC decision:

  1. Recommendation 7.0: For the current health care worker, public or private, participation in educational and certification programs such as AMIA 10x10 program, HIM progression and certificate programs, European Computer Driver’s License equivalent, and other programs for basic/core HIT competency training and evaluation should be encouraged through bonus criteria, training programs, or other means. AHIC decision: Accepted

  1. Recommendation 8.0: ONC should work with the states to encourage governors to increase recognition of health IT workforce needs and suggest ways to address them. This could include health professional licensing activities. AHIC decision: Accepted

** CPS & EHR Workgroups’ review & reponse on the “Recommended Requirements for Enhancing Data Quality in Electronic Health Record Systems” can be viewed at: http://www.hhs.gov/healthit/documents/m20080115/11-cps-ehr_recs_ltr.html