AHIMA: Stage 2 should allow patients to restrict access to certain data
Regarding privacy and security of a patient’s health record, individuals should have the right to restrict certain services from disclosure, stated the American Health Information Management Association (AHIMA) in its comments on Stage 2 draft recommendations for the Centers for Medicare & Medicaid Services' (CMS) EHR incentive program.
“We support the capability to place restrictions on certain data that has been merged into an EHR from various sources,” the association stated.
AHIMA’s other comments and recommendations included:
AHIMA also urged the HIT Policy Committee to consider the number of other regulatory initiatives developing with a compliance time frame of 2013, and suggested aligning these programs to allow for a coordinated approach to implementation and production. In addition, the association voiced concerns about the proposed Stage 2 requirements for computerized provider order entry.
“Members are concerned there may be redundancy issues associated with changing from 'more than 30 percent unique patients’ in Stage 1 to ‘60 percent of prescription, lab and radiology orders…’ This is a significant change in the way the objective is calculated in Stage 2 and adds complexity and administrative burden in capturing orders not documented electronically. We request further guidance be developed on the numerator/denominator calculations and how certification rules associated with this objective will be defined and tested,” the association stated.
Click here to see all of AHIMA’s comments.
“We support the capability to place restrictions on certain data that has been merged into an EHR from various sources,” the association stated.
AHIMA’s other comments and recommendations included:
- When a provider chooses not to adhere to clinical decision support (CDS) at the point of care, the provider should document why he or she chose not to follow a certain workflow. When treatment of care deviates from the direction guided by the CDS, this should be captured and included in the reporting for meaningful use.
- With regard to the HIT Policy Committee’s Stage 3 proposed requirement to accept and integrate externally generated health information, this information must be uniformly flagged or differentiated from internally generated health information, and there must be a uniform, consensus standard for such flagging. “Given the meaningful use timetable, this vocabulary set must be developed as soon as possible,” AHIMA stated.
- State laws might impact the process of redisclosing health information originating from another source that is stored within an HIE. Organizations must understand their redisclosure responsibilities under all relevant federal and state laws. “[T]here is a web of state laws to consider in this process,”the statement read.
AHIMA also urged the HIT Policy Committee to consider the number of other regulatory initiatives developing with a compliance time frame of 2013, and suggested aligning these programs to allow for a coordinated approach to implementation and production. In addition, the association voiced concerns about the proposed Stage 2 requirements for computerized provider order entry.
“Members are concerned there may be redundancy issues associated with changing from 'more than 30 percent unique patients’ in Stage 1 to ‘60 percent of prescription, lab and radiology orders…’ This is a significant change in the way the objective is calculated in Stage 2 and adds complexity and administrative burden in capturing orders not documented electronically. We request further guidance be developed on the numerator/denominator calculations and how certification rules associated with this objective will be defined and tested,” the association stated.
Click here to see all of AHIMA’s comments.