| Comment Number: | 534908-00004 |
| Received: | 4/24/2008 11:41:24 AM |
| Organization: | DocSite, LLC |
| Commenter: | John Haughton |
| State: | MD |
| Agency: | Federal Trade Commission |
| Rule: | Health Care Delivery |
| No Attachments |
Comments:
HIT innovation. The current federal government requirement for CCHIT certification for some of the demonstrations and quality projects certifies for standards in an all or nothing way rather than effectiveness in improving care and offering a modular approach to certification of different aspects of care improvement - including e-prescribing and clinical decision support. Premature global certification stifles innovation that is valuable for customers - in this case physicians buying healthcare information technology. We believe that the FTC should weigh in to keep market innovation for the customer open, that is push for standards on "what" gets accomplished, rather than "how" it gets accomplished. Addtionally, we would like the FTC to work with HHS to help them understand the market impact of decisions they make on funding various pilot initiatives. The Healthcare Technology Sector is not a mature sector. As such, predefining the effective "how tos" - eg CCHIT criteria vs the desired "whats" - eg improved care - may stifle innovation. Additonally, CCHIT currently requires an "all or nothing" approach rather than allowing an incremental adoption strategy based on value - eg adding e-prescribing then clinical decision support or vice versa at the point of care to improve quality of care delivered. The British Medical Journal published an article in 2005 showing that the most important elements of improving care included getting decision support into the clinical workflow at the point of care. Farzad Mostashari MD, head of NYC Primary Care Info Project testified to congress in the fall of 2007 and re-emphasized in an editorial in the Journal of the American Medical Association that the CCHIT certified EMR purchased for the New York primary care project would have to be modified as it did not offer the functions necessary to improve care: 1) Structured data collection 2) Decision support tools with alerts and reminders 3) Patient Registry functions 4) Population Quality Measurement. Healthcare needs improvement and will improve. Any help in nurturing an immature market is appreciated. John Haughton MD, MS CEO DocSite, LLC www.docsite.com 919 256-9510