CPeH
June 11, 2009
Charles Friedman
Deputy National Coordinator for Health Information Technology
Office of the National Coordinator for Health Information Technology
United States Department of Health and Human Services
200 Independence Ave, SW., Suite 729D
Washington, DC 20201
Attention: Health IT Extension Program
The Consumer Partnership for e-Health is a coalition of consumer, patient and labor
organizations working toward a patient-centered health care system, enabled by health
information technology and sharing of knowledge. Effective, meaningful use of HIT is an
essential element of achieving the fundamental shift from a delivery system that is
centered on the needs of providers and payers, to one that emphasizes active consumer
participation and meaningful partnerships between patients and providers to support
health improvement – a patient-centered health care system.
Redesigning health care systems and processes around the needs of patients is a
daunting task for providers who are caring for patients in an increasingly complex health
care environment. To be successful, providers require significant support, and the HIT
Regional Extension Centers will be a critical part of that support.
We submit these comments in response to HHS’ draft description of a program for
establishing regional centers (Centers) to assist providers seeking to adopt and become
meaningful users of health information technology.
Our comments focus on the following broad recommendations for clarifying and further
developing the program description to meet the overall goal of assisting providers in
using HIT as an enabler of patient-centered care:
1. Clarify the scope of work to focus on systems redesign to achieve patientcentered, high quality care, including, but not limited to, meaningful use of HIT.
2. Include in the scope of work assistance to providers for using HIT to engage
consumers and support their active health management.
3. Integrate privacy and security issues into the mission of the Regional Extension
Center program.
1. Clarify the scope of work to focus on systems redesign to achieve patientcentered, high quality care that reduces disparities, including, but not
limited to, meaningful use of HIT.
A narrow focus on selection and successful implementation of certified electronic health
records, without redesigning the systems and processes for providing care according to
clearly defined, patient-centered goals will result in limited return on the investment our
nation is making in HIT. We know that planning and implementation assistance is
essential to avoid implementation failure. Goal setting is a key step in the planning
process, and the Centers will be invaluable resources for helping providers set
meaningful goals, redesign their care processes to enable meeting those goals, and
select electronic systems that support their new processes as part of their
implementation assistance. As drafted, the goals of the proposed program do not
provide direction to grantees for how to structure their work in ways that will help
providers successfully redesign their care processes to more effectively meet the needs
of the patients they serve. We suggest clarifying the goals to focus on systems redesign
that includes, but isn’t limited to meaningful use of HIT, and making them measurable
and more closely reflective of statutory requirements for prioritizing assistance to small
providers serving vulnerable populations, as well as achieving specific outcomes related
to the meaningful use of HIT.
A useful framework for these goals has already been established by the National
Priorities Partnership, convened by the National Quality Forum. Their 2008 report
entitled “National Priorities and Goals” identified a set of national priorities to help focus
performance improvement efforts. Included among the priorities were patient
engagement, reduction of racial disparities and coordination of care, all of which are key
expectations of patient-centered care that are enabled by HIT. These priorities are
being used to guide the short and long term definition of “meaningful use” of an
electronic health record, which is linked to incentives for adoption. By aligning the
Exchange Center program goals with the broader purpose of patient-centered care as
reflected in the NPP priorities, the centers and providers would be incentivized to work
together to achieve targeted outcomes, which could then be incorporated into a robust
program evaluation.
2. Include in the scope of work assistance to providers for using HIT to
engage consumers and support their active health management.
A key element of patient-centered care is providing patients access to their own
personal health information and meaningful, actionable information about their
particular health needs. In fact, more active engagement of consumers in their health
and health care will in many cases require significant process redesign. Therefore it is
highly appropriate that as the Centers work with providers on redesigning their care
processes, they intentionally address providers’ needs for training on how to use HIT to
engage consumers. Specifically, Centers should help providers use health IT to support
patients’ active health management by allowing them to see what is in their electronic
health record, taking advantage of “teachable moments” by showing patients charts and
graphs of key health indicators, such as HbA1c levels, sharing information directly with
patients by populating PHRs or other patient-controlled tools, and delivering care in a
more patient-oriented and responsive way (including through electronic communication
tools, remote monitoring, reminders, online scheduling, and mechanisms for shared
decision-making).
The workflow and care processes used by most providers not only do not support such
patient-engaging activities, but often are barriers to it. Redesigning care processes to
be more efficient or more clinically effective will still fall short of the goal of patientcentered care if providers do not also use the technology to engage patients as active
partners in their care. As a result, the full benefit of HIT enabled care will not be
realized. To that end, we recommend that in order for multi-stakeholder collaborations
to be given preference during the selection process they must include a consumer or
patient organization.
Another role HIT can play in patient engagement is providing a method of incorporating
patient generated data into the clinical context for individualized care. Such data might
include blood pressure readings, daily weights, or symptoms that are important pieces
of information for clinicians to use in making clinical diagnoses and recommendations for
treatment. Such information is also essential for care planning and shared decisionmaking. Centers must play a central role in ensuring that providers are able to integrate
this data as part of providing patient-centered care.
3. Integrate privacy and security issues into the mission of the Regional
Extension Center Program.
A foundational element of patient-centered care is respecting and protecting the privacy
of personal health information. The inclusion of privacy and security as a best practices
topic for the Centers is commendable, but we feel they should be incorporated into the
mission of these organizations. We fully endorse the recommendations of the Center for
Democracy and Technology in its letter on this topic (see Addendum). Consistent with
their recommendations, we believe that the Centers should be a critical interface with
the regional privacy officers, providing a feedback loop of information about how privacy
and security rules and guidance are being implemented, areas needing clarification, and
challenges to implementation. Such feedback is critical to ensuring privacy while also
enabling the appropriate flow of information.
Thank you for the opportunity to comment on this exciting, and extremely important
program. We look forward to working with the Regional Exchange Centers to achieve a
patient-centered health care system.
Sincerely,
Members of the Consumer Partnership for eHealth
The National Partnership for Women & Families