USACM Comments on Electronic Health Records
USACM submitted its public comment on the proposed new and revised certification standards and implementation specifications that define the technological capabilities, functionality, and security of health information technology and electronic health records used in the Medicare and Medicaid Incentive Programs.
The proposed new and revised certification standards are part of the national effort to modernize our healthcare infrastructure under the Health Information Technology for Economic and Clinical Health Act (HITECH Act). The goal is to provide better managed patient care through improved health information technology and electronic health records.
The Medicare and Medicaid Incentive Programs provide payments to eligible professionals and hospitals to help them adopt, implement, and upgrade their technologies. To receive incentive payments, healthcare providers must use certified technology. The certification gives healthcare providers the confidence that their IT systems and electronic health records will be secure, accurate, and interoperable with other providers. Patients can be assured that the providers are using certified technology to protect the security, privacy, and confidentiality of their health records.
USACM endorses the proposed enhancement to the certification standards to require accessibility of patients’ electronic health records. USACM agrees that all patients should have equal and meaningful access to their electronic health information. The proposed adoption of the Web Content Accessibility Guidelines (WCAG), an international technical standard for web accessibility, and its Level AA conformance criteria will enhance the ability of patients, including patients with mobility or visual impairments, to access their electronic health information. The international standard is technology-independent and is supported by freely available online documentation. Other federal agencies, including the Access Board, similarly are considering adopting WCAG and its Level AA conformance criteria as the minimum standard for web accessibility. Read the USACM and SIGCHI public comment to the Access Board in March 2012 on improving the accessibility of federal websites.
The new certification standards for health information technology and electronic health records, once adopted by the U.S. Department of Health and Human Services, will take effect for healthcare providers in fiscal year and calendar year 2014.