To advance the goal that federal health IT policy facilitates better care, better outcomes and lower costs for patients and families, the Consumer Partnership for eHealth (CPeH) provided comments this week on the draft 2015 Edition of Electronic Health Record (EHR) Certification Criteria, released by the Office of the National Coordinator (ONC) in February. CPeH’s comments largely support the proposed rule, specifically its inclusion of patient- and family-centered criteria and key tenets of CPeH’s Disparities Action Plan. To receive incentive payments under the federal program, providers must use certified Electronic Health Record (EHR) technology in meaningful ways. CPeH’s recommendations focus on the need to incorporate key functions into certified EHRs more quickly to reduce health disparities and improve patient-centered care planning.

“If adopted, the Proposed Rule is an important next step in the ongoing effort to make sure EHR technology includes essential functionalities that will help meet the needs of patients and families,” said Debra L. Ness, president, National Partnership for Women & Families, which leads CPeH. “We are pleased the proposed rule advances the goal of leveraging the Meaningful Use Incentive Program to better identify and reduce health disparities, which are a pervasive and costly problem in our country.” 

CPeH’s comments: 

• Recommend that ONC require more granular collection and filtering of patients’ race and ethnicity, using at least the standards set by the U.S. Department of Health and Human Services. One example of the benefits of doing so is that studies show that Asian-Indian adults are three times more likely to have diabetes than Japanese-American adults, but are less likely to have hypertension. When Asian-Indian patients and Japanese-Americans are grouped together as simply “Asian,” providers cannot easily distinguish patterns or tailor patient care to reflect individualized health risks. 
• Recommend that EHR technology be capable of providing patient-specific education resources in a patient’s preferred language as soon as possible.  Given that more than 60 million Americans speak a language other than English at home, this functionality is critical to ensuring every patient can understand information relevant to his/her care. At the very least, the 2015 edition should be able to provide 100 percent of education materials in Spanish. By 2017, EHRs should provide education materials in at least the top five national languages. 
• Urge ONC to require EHRs to link to or provide directions to the content of a patient’s advanced directive, rather than just note its existence. This will ensure that providers are able to respect patients’ wishes.  CPeH also urges ONC to require this functionality to be available to all patients, regardless of age.
• Support ONC’s proposal to require EHRs to collect additional demographic data, such as patients’ disability status and sexual orientation and gender identity (SO/GI), by 2017.  Such information has great clinical relevance and is vital not only for making care truly patient-centered, but for improving health outcomes.

Ness added, “Given the grave harm disparities cause to patients and families, as well as the strain placed on our health care system by unequal and inefficient care, criteria developed to tackle disparities should be incorporated into EHR technology more quickly than ONC has proposed. We won’t significantly decrease long-term health care costs unless we reduce disparities, and health IT has the potential to be a game-changer in that effort.”

The following organizations have endorsed the comments: AARP; American Association of Birth Centers; American Association on Health and Disability; American Federation of State, County and Municipal Employees (AFSCME); American Heart Association/American Stroke Association; Asian & Pacific Islander American Health Forum; Association of Asian Pacific Community Health Organizations; Bechtel Health; California Center for Rural Policy; Center for Democracy & Technology; Community Action Partnership;  Consumers Union; Disability Policy Consortium; Family Caregiver Advocacy; Disability Rights Education and Defense Fund; Fenway Institute; Futures Without Violence; Healthwise Inc.; Health Access California; Informed Medical Decision Making Foundation; National Consumers League; National Council of La Raza; National Health Law Program; National Senior Citizens Law Center; National Partnership for Women & Families; Summit Health Institute for Research and Education, Inc.; The Arc of the United States; The Children’s Partnership; and Mary Anne Sterling, Family Caregiver Advocate.