The Medical Library Association’s (MLA) comments address the following areas:
1) The definition and criteria of meaningful use; 2) access to knowledge-based information by health professionals; 3) the use of patient-specific education resources as a component of meaningful use for engaging patients and families in their health care; 4) ensuring the privacy and security of patient records; and 5) interoperability of records.
Definition of Meaningful Use. MLA supports the intent of Congress that the broad goal to be accomplished through the definition of meaningful use of certified EHR technology for expanding the use of EHRs should be that:
“Certified EHR technology used in a meaningful way by providers is one piece of a broader HIT infrastructure needed to reform the health care system and improve health care quality, efficiency, and patient safety.” And that “ultimately, consistent with other provisions of law, meaningful use of certified EHR technology should result in health care that is patient-centered, evidence-based, prevention-oriented, efficient, and equitable” (The American Recovery and Reinvestment Act of 2009, Pub.L. 111-5; Sec. 1848 (o)(2)(A) and as added by sections 4101(a) and 4102(a) of the HITECH Act).
Access to knowledge-based information (KBI). To fully achieve the priority: “improving quality, safety, efficiency, and reducing health disparities,” MLA maintains that the technology must have the capability of allowing health professionals access to clinical decision support resources at the point of care—that is, access to the scientific literature. The proposed regulation identifies care goals that call for the use of evidence-based order sets and CPOE; and applying clinical decision support at the point of care,” however, the objectives and measures associated with these care goals do not address access to and the use of the scientific literature (e.g., Medline) under the criteria for meaningful use. We recommend that this be incorporated into the regulation.
Patient-Specific Education Resources. MLA also maintains that achievement of the goals for meaningful use must provide for the technology to enable patients and their families with access to data, knowledge, and tools to make informed decisions and to manage their health as outlined in the August 2009 recommendations of the Health Information Technology Council to the National Coordinator for Defining Meaningful Use. We note the decision not to include the objective, “Provide access to patient-specific education resources upon request,” and understand the rationale for its exclusion in Stage 1. However, we urge that this objective be integrated into the criteria for meaningful use as early as possible, and no later than 2013. We are encouraged that HHS plans to work with the HIT Policy Committee, NLM, and experts in this area to ensure the feasibility of this measure in the future, and that the January 2010 report of the HIT Policy Committee already reports progress in this area as a result of discussions with these groups.
Privacy and Security. In general, MLA is pleased to see provisions that will allow patients timely electronic access to their health information, and also provisions to ensure the privacy and security of these records.
Interoperability of Records. We continue to support the widespread adoption of national standards that support the interoperability, transportability, and security of electronic health records including the standard clinical terminologies (SNOMED CT, LOINC, RxNorm) and Unified Medical Language System resources supported or built by the National Library of Medicine.