HIMSS offers suggestions to improve ONC IT safety plan

The Healthcare Information and Management Systems Society (HIMSS) is supporting much of the Office of the National Coordinator for Health IT’s proposed HIT safety plan, but its comment letter offers additional ideas to enhance or clarify some of the provisions.

For instance, the society is concerned that a provision to have ONC-Authorized Certification Bodies (ACBs) incorporate IT safety in post-market surveillance of certified EHR technology is too broad and the ACBs lack core competencies on safety. "Given ONC’s intent to leverage the [patient safety organization] reporting system and the AHRQ common format, we are concerned that adding an ACB component may not serve ONCs overall goal of efficacy. We note that an ACB appendage for reporting may create an unnecessary level of complexity due to the potential for generating unfiltered reports in the absence of an analytic or response mechanism that fits into the overall reporting system."

The plan calls for Meaningful Use of EHR technology to improve patient safety and "HIMSS agrees that it makes sense to prioritize items for Meaningful Use that exhibit a patient safety benefit (e.g. CPOE, med lists, etc.). We continue to encourage alignment of the EHR Incentive Program’s quality reporting requirements with other federal reporting/incentive programs. In terms of the requirement for a safety risk assessment, we suggest that this could be a premature step—in lieu of standards, this may be burdensome to providers."

The plan also calls for support to patient safety organizations (PSOs) to identify, aggregate and analyze health IT safety event and hazard reports.

"HIMSS supports voluntary reporting using the AHRQ Common Data Format, with refinements as appropriate to meet the needs of health IT users, including those in ambulatory settings. We note that much of event report aggregation happens too late to allow for adequate response time to immediate issues, and therefore emphasize the importance of two key activities that ONC should emphasize in the final report:
• Recognition of the critical importance of direct provider reporting to, and consulting with, their EHR developer when conducting root cause investigations; and
• Inclusion of IT developers in the PSO primary work with reporting providers, and other components of the protected PSO process."

Unlike some commenters, HIMSS does not take a stand on the issue of creating a national patient identification system, but noted that it has asked Congress to direct a study of the issues and best approaches to identify an appropriate national patient data matching strategy.

The complete comment letter is available here.