The Department of Health and Human Services (HHS) should maintain the strength of its proposed rule on the Electronic Health Record (EHR) Incentive Program because it delivers the benefits consumers deserve in return for their tax dollars as well as the tools they need to be actively engaged in their health. That is the central message in a 19-page comment letter filed today by members of the Consumer Partnership for eHealth, a non-partisan group of consumer, labor and patient organizations, and the Campaign for Better Care, a coalition of consumer organizations working on behalf of older adults with multiple health conditions and their families. These two coalitions include many of the nation’s largest organizations representing patients and consumers of all kinds.

In the comment letter, they applauded the proposed rule which, for the first time acknowledges and incentivizes the crucial role that care providers play in helping patients understand how to use their health information in partnership with doctors to improve outcomes. But the comments filed today highlight the fact that the proposed rule offers benefits that go far beyond building knowledge and understanding among patients and caregivers. These two coalitions note that holding providers accountable for helping their patients to use their information also:

• Conveys an expectation from their provider that patients become active participants in, rather than passive recipients of, care something the provider community has long advocated;

• Fosters a change in clinical culture from paternalism to partnership; and

• Significantly and positively affects their experience with the value of EHRs, which one study shows increases consumer trust in these systems.^[1]

“HHS made bold progress in this rule, which will positively impact the quality and experience of care for millions of Americans in tangible, life-saving way,” said Christine Bechtel, vice president of the National Partnership for Women & Families, which leads both coalitions, and member of the federal Health IT Policy Committee. “But as strong as it is, there are two key areas where it should be strengthened in order to deliver the kind of value consumers need and deserve. The first is care coordination. Given the importance of health information exchange to broader health reform efforts, the fact that Stage 2 requirements will not go into effect until 2014 and will be in effect for perpetuity, requiring exchange of key information in only 10 percent of transitions and referrals is an extremely low bar, unworthy of public incentives. The second area where improvement is needed is health equity. Providers in Stage 1 began collecting information that is critical for understanding and reducing disparities in care. But they were not required to use this information in any way. In Stage 2, we need to incentivize providers to use this information to guide improvements that will decrease disparities in care, and ultimately benefit everyone.”

The comment letter says the proposed rule will improve the way care is provided, and urges the Department of Health and Human Services to stand strong in the face of opposition from those who argue that these critical changes are too much, too soon. “Patients have waited long enough for a health care system that truly meets their needs,” Bechtel added. “Now is the time to make the progress patients and our health care system urgently need.”

Read the full comment letter here

[1] “Making IT Matter: How Consumers Value and Trust Health IT.” National public opinion survey of 1,961 adults conducted from August 3 to August 22, 2011. More at www.nationalpartnership.org/HIT