Collaborative Outreach
Office of the National Coordinator (ONC) Federal Advisory Committee Public Comments:
On May 6, 2012 the Pharmacy e-Health Information Technology Collaborative (Collaborative) provided comments to the Office of the National Coordinator for Health Information (ONC) to the ”Health Information Technology: Standards, Implementation Specifications, and Certification for Electronic Health Record Technology, 2014 Edition; Revisions to the Permanent Certification Program for Health Information Technology Notice of Proposed Rulemaking” published in the Federal Register on March 7, 2012. The Collaborative submits a cover letter explaining its comments. The Collaborative is supportive of the proposed revisions to the permanent Certification Program for Health Information Technology as it applies to the objectives of the EHR Incentive Program in Meaningful Use—Stage 2; however, we are concerned that some of the proposed measures will become unfunded mandates (these areas are noted throughout our attached comments). Pharmacists are ineligible for EHR incentives, though they will need to exchange information with EHR systems to connect to and ensure needed bidirectional communication with EPs. As implementation of Stage 2 moves forward; especially with regard to the certification criteria for EHR technology, it should not create additional or financial burdens on pharmacists, such as becoming an unfunded mandate.
Federal Advisory Committee HIT Policy Committee (HITPC) Certification and Adoption Work Group Meeting April 13, 2012 - Collaborative Director's Public Comments
HIT Policy Committee January 10, 2012 - Collaborative Director's Public Comments
The Office of the National Coordinator for Health Information Technology (ONC); request for comments regarding Metadata Standards to Support Nationwide Electronic Health Information Exchange. The Collaborative's 9-23-11 Comments.
Proposed rule, Medicare Program:Shared Savings Program: Accounatable Care Organizations (ACOs) and Medicare Program: Waiver Designs in Connection with the Medicare Shared Savings Program and Innovation Center (42 CFR 435). The Collaborative's comments focus on ensuring the HIT clinical and functionality measures necessary to ensure that pharmacists may exchange data as partners in ACOs. The Collaborative is not commenting on the Medicare Program: Waiver Designs in Connection with the Medicare Shared Savings Program and Innovation Center. The 6-6-11 Comments.
The Office of the National Coordinator for Health Information Technology (ONC); request for comments regarding Policy and Technology Framework for Health Information Exchange (HIE): Privacy and Security Issues. The Collaborative's 5-9-11 Comments.
The Office of the National Coordinator for Health Information Technology (ONC); request for comments regarding Federal Health IT Strategic Plan. The Collaborative's 5-6-11 Comments.
The Office of the National Coordinator for Health Information Technology (ONC); request for comments regarding Meaningful Use Stage 2 Objectives. In addition, is the 2-25-2011 General Comments and the 2-25-2011 Request for Comments on the MU Objectives and Measurements for Stage 2 and Stage 3 spreadsheet.
The Office of the National Coordinator for Health Information Technology; Health Information Technology; Request for Information Regarding the President's Council of Advisors on Science and Technology (PCAST) Report Entitled ''Realizing the Full Potential of Health Information Technology To Improve Healthcare for Americans: The Path Forward. The Collaborative's 1-17-11 Comments.
HIT Standards Committee requested comments on new initiatives being considered by ONC through the Standards and Interoperability ( S&I ) Framework. The Collaborative's 12-22-10 Comments.
HIT Policy Committee Quality Measures Workgroup requested comments on the meaningful use (MU) of the electronic health record (EHR) quality measurement concepts to be included in Stage 2 and 3 measurement goals 12-22-10 Comment Spreadsheet. In addition, are the 12-22-10 General Comments.
On October 21, 2010 the Collaborative sent a letter to HHS Secretary Sebelius
HIT Policy Committee October 20, 2010 - Collaborative Director's Public Comments
HIT Standards Committee Implementation Work Group October 7, 2010 - Collaborative Director's Public Comments
HIT Standards Committee September 21, 2010 - Collaborative Director's Public Comments
HIT Policy Committee Quality Measures Work Group September 10, 2010 - Collaborative Director's Public Comments
CMS Comments
On May 6, 2012, the Pharmacy e-Health Information Technology Collaborative (Collaborative) provided comments to the Centers for Medicare and Medicaid Services (CMS) request for comments the “Medicare and Medicaid Programs; Electronic Health Record Incentive Program – Stage 2 Notice of Proposed Rulemaking” published in the Federal Register on March 7, 2012. The Collaborative recommends that CMS consider allowing pharmacists to become eligible professionals (EPs) in the Electronic Health Record (EHR) Incentive Program. The Collaborative is very supportive of the proposed measures and objectives for the EHR Incentive program; however, our concern is that the proposed measures and objectives will become unfunded mandates (these areas are noted throughout our comments below). Pharmacists are ineligible for EHR incentives, though they will need to exchange information with EHR systems to connect to and ensure needed bidirectional communication with EPs. Today, that exchange is not at an adequate level. Pharmacists have standards in place to meet these requirements. As implementation of Stage 2 moves forward, it should not create additional or financial burdens on pharmacists, such as becoming an unfunded mandate. Also as our comments indicate, allowing pharmacists the opportunity to become EPs and receive EHR incentives may lead to adoption of these EHR standards at a level that may be significant.
The Collaborative recommends that "data requirements" (the information or data that is required to be populated in fields of standardized formats) for medication therapy management (MTM) electronic transactions are incorporated into the "Standardized Format for the Comprehensive Medication Review Action Plan and Personal Medication List Summary". Furthermore, the Collaborative members' request clarification on printing formats and if CMS expects standardized forms to be printed in the specific format as presented in the draft or if there is flexibility in how pharmacies can print the forms utilizing their software systems. The Collaborative members' recommend that CMS consider flexibility in the format of the standardized forms and should allow an electronic media if available.
The Collaborative recommends that data requirements for MTM electronic transactions are incorporated into the "Standardized Format for the Comprehensive Medication Review Action Plan and Summary". This would assure completion of the forms for the patient is driven off existing electronic data elements so that rekeying will not be necessary. This recommendation is supported through the American National Standards Institute (ANSI) Standard Development Organizations including National Council for Prescription Drug Programs (NCPDP), Accredited Standards Committee (ASC X12), and Health Level Seven (HL7) processes to assure Medication Therapy Management Services (MTMS) electronic standard transactions are developed. The Collaborative supports and works with these organizations to make certain data elements such as those in the proposed forms are populated from the "Pharmacist EHR" and or other types of interoperable electronic systems.
HHS Comments
On May 6, 2012 the Pharmacy e-Health Information Technology Collaborative (Collaborative) provided comments to the “Request for Information on Prescription Medication Adherence” published in the Federal Register on April 5, 2012. Pharmacists play an important role in optimizing medication adherence, therapeutic outcomes and eliminating many of the issues that cause medication non-adherence. In their role, pharmacists promote safe, efficacious, cost-effective medication use to achieve definite outcomes through the responsible provision of drug therapy that improve a patient’s quality of life. Pharmacists are key resources that help bridge the gap between physicians and patients. Pharmacists can provide needed medication information and education to patients concerning their drug therapy that physicians and other health care providers may not have, and encourage and improve prescription medication adherence in patients. Additionally, the bidirectional exchange of clinical information with pharmacists, especially through electronic health records (EHRs), will help ensure prescription medication adherence.
The Collaborative generally supports the goals of the Department of Health and Human Services (HHS) to allow individuals to receive information regarding uses and disclosures of protected health information to assist providing greater transparency regarding the uses and disclosures of information. However, the Collaborative is concerned that the NPRM is an overly burdensome requirement for covered entities. Specifically, the time and resources investment required to implement systems to track and monitor uses and disclosures of PHI, including for treatment, payment, and operations and to closely monitor uses and disclosures by business associates is costly relative to benefit. The Collaborative suggests that HHS withdraw the rule as proposed and work with stakeholders to develop a rule that is more consistent with the provisions implemented under HITECH.