a record of care for legal, business, and disclosure purposes.”
“An EHR system must be able to create, maintain, and man-
age records within a framework of ever-changing jurisdictional
rules, regulations, and laws that are intended to assure electron-
ic records are valid, accurate, and trustworthy,” Viola wrote.
Transfer of Records
Several provisions of the proposed rule address the ability to
transfer a patient’s record from one provider to another in a
meaningful way. One criterion requires providers to furnish a
summary of care record for each transition of care or referral.
AHIMA supports ONC’s considered requirment of specific
data element captures in transition of care. “We believe this will
ensure a consistent list of data that must be captured and submitted to the receiving setting of care or provider,” Viola wrote.
But AHIMA does not support the suggested rule requirement
that certified EHR technology include a requirement for performing demographic matching. Instead, any patient matching function should be external to the EHR and use specialized
technology focused on identity management, Viola wrote. Since
correct patient identification should occur before any EHR-based clinical data capture or creation, usually at registration,
demographic matching processes should be developed to catch
ambiguities before clinical treatment. Relying on “some type”
of demographic matching required in the EHR runs the risk of
facilities relying on this as their “only type” and ignoring other
data stewardship and early patient identification functions.
The certification proposed rule also states that facilities receiving a patient from another setting of care should perform a medication reconciliation using EHR technology. AHIMA supports
the inclusion of this requirement in the final certification rule.
requirements, such as the inclusion of the Agency for Healthcare Research and Quality’s current Patient Safety Organization
Common Format program that captures information about patient safety events.
While AHIMA feels it is imperative that health data be captured in an accurate and timely manner by EHRs to “support the
care and safety of patients,” the association spoke out against requiring the implementation of new patient safety design components since EHR vendors could face significant challenges
implementing these new components by 2014.
“This requirement should remain optional to allow the vendor community to focus on the human factors, safety culture,
and usability of their EHR systems,” Viola wrote. “We encourage
ONC to consider this as a requirement for stage 3 thus allowing
time for developers and users of the systems to assess the new
features.”
Miscellaneous Comments
AHIMA made several other miscellaneous comments to ONC
about the certification proposed rule specifics.
The proposed rule steps up security standards. One requirement calls for EHR systems to encrypt data at rest in order to
help prevent unauthorized access. AHIMA said it “strongly supports” this proposal.
ONC proposed the use of SNOMED CT for several meaningful
use objectives, including recording problem lists. AHIMA said it
supports the use of SNOMED CT for “optimal clinical data cap-
ture and reuse of information captured in problem lists.”
To read AHIMA’s complete certification comments, visit www.
ahima.org/advocacy. ¢
Patient Safety Requirements
Chris Dimick ( chris.dimick@ahima.org) is staff writer at the Journal of
AHIMA.
New certification criteria calls for more safety-enhanced design
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