AHA commends ONC for patient safety policy, pushes for MPI

The American Hospital Association (AHA) has issued a letter to the Office of the National Coordinator for Health IT (ONC) to congratulate the agency on its patient safety action plan that recognizes the shared responsibility of vendors, clinicians, providers and federal agencies in ensuring that health IT systems are designed, implemented and used to mitigate harm and promote safety. However, the association also encouraged more focus on a single, national master patient index (MPI).

The AHA concurred with the plan’s approach to build on “existing patient safety efforts across government programs and the private sector.” They embraced the “culture of safety” called for in ONC’s plan as the best approach to prioritizing patient safety and identifying and correcting safety concerns. Also, they agreed that health IT is most appropriately considered as one of many factors affecting safety, rather than as a topic on its own.

The association encouraged ONC to assume a coordinating role in this endeavor and caution against an approach that leads to duplicative efforts. In particular, the Agency for Healthcare Research and Quality has been a good partner on safety issues, and the AHA said it is “encouraged that the safety plan recognizes AHRQ’s unique role.”

With regard to the Centers for Medicare & Medicaid Services, the AHA noted that changes under the Conditions of Participation (CoPs) must be supported by clear evidence of what is essential safe practice and go through the rule-making process. If and when the CoPs for hospitals are updated, the association encouraged ONC to consider how corresponding safety standards could be built into certification requirements for EHRs vendors.

The AHA commended ONC for establishing specific steps to encourage EHR vendors to take responsibility for the safe design, implementation and use of their products, including good quality management principles, user-centered design and human factors assessment.

The AHA supported the development of a voluntary code of conduct for EHR vendors with specific commitments to ensuring and promoting safety. The code of conduct should make it clear that vendors are responsible for safe design and product development and will support safe use of their products. In addition, the code of conduct should discourage vendors from including in their contracts indemnity clauses or nondisclosure language that limits the capability of users to identify and raise safety concerns, according to the AHA. The code of conduct also should address other areas, such as transparency in pricing and adherence to existing coding conventions for systems that support billing.

The AHA supported the elements of ONC’s 2014 edition certification criteria that support safety-enhanced design, including adherence to quality management principles and processes and user-centered design. As indicated in the safety plan, these elements of certification should be considered a starting place, and continue to evolve as the healthcare community learns more about safe design and the interaction between usability of EHRs and patient safety.

Further, the AHA urged ONC to focus its efforts on a patient safety issue that received limited mention in the safety plan—a single, national approach to matching patients to their records that all parties can use. “The issue of how to match patients with their medical records needs to be solved as we accelerate health information exchange (HIE) on regional and national levels,” the association wrote. “The inability to match patients across silos raises safety concerns about mismatches – incorrectly matching patients, or missing a match that should have been made. In addition, without a single, national approach to patient matching, hospitals and health systems are forced to expend significant resources on expensive, proprietary solutions to develop master patient indexes that apply only to that particular hospital or health system’s patients.”

Finally, the association noted that the safety plan did not mention the key role of HIE to support the safety benefits of EHRs. To that end, they encourage ONC to focus considerable resources on advancing the more robust data exchange infrastructure necessary to support the sharing of health information.