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Saturday, June 20, 2009

"Meaningful Use" Public Comment Deadline - June 26, 2009

Last February, President Obama signed into law the Health Information Technology for Economic and Clinical Health (HITECH) Act, which provides $17.2 billion to physicians and healthcare enterprises that qualify as "meaningful users" of certified electronic health record (EHR) technology. This week, the HIT Policy Committee issued a draft definition of "meaningful use" and requested that members of the public submit comments concerning the definition. The committee’s request provides us with a tremendous opportunity to educate government decision-makers on the crucial role that medical transcriptionists play in clinical documentation by ensuring the accuracy and completeness of patient health records.

Please submit your comments to the HIT Policy Committee by sending an email to meaningfuluse@hhs.gov and placing "Meaningful Use" in the subject line. So that we are all sending a consistent, unified message on this subject, we strongly recommend that you incorporate some or all of the following points (in your own words) when you submit your comments to the Committee:

• EHR technology has the potential to improve quality of care, enhance patient safety, and reduce healthcare costs. However, successful adoption and implementation hinges upon the effective integration of technology and people, including physicians, other healthcare providers, and medical transcriptionists (MTs)/healthcare documentation professionals who work alongside physicians to ensure that patient records are accurate and complete.

• While these technologies have improved documentation, an "extra set of knowledgeable and skilled eyes" is still needed to ensure the accuracy and completeness of patient health records. To free up clinicians to focus on patient care, not data entry, in the new age of EHRs, healthcare documentation specialists will capture and correct errors that otherwise would become permanent and be perpetuated in a patient’s health record, potentially creating misinterpretation by other care providers and compromised care of the patient.

• Dictation has historically been and continues to be the documentation method of choice for physicians because it produces a complex, specific narrative that ensures accurate capture of patient history, as well as the care encounter. By allowing for uniformly formatted and coded narrative reports, EHR technologies will enable this vital piece of the patient health record to be shared across providers and enterprises.

• Incorporating dictation-transcription and uniformly formatted and coded narrative reports into the certification process for EHR technologies and the definition of "meaningful use" is a simple, yet proven and highly effective, way to ensure that improved health information capture supports and improves the quality of patient care delivery. It also will add no cost to the system and will likely save money using more cost effective healthcare documentation specialists to capture data rather than expensive clinicians.

Guidelines to consider when submitting your comments to the HIT Policy Committee:
1. Submit your comments no later than 5:00 p.m. EDT on Friday, June 26, 2009.

2. Add to the strength of your comments — if you are an MT, include a personal story or two detailing errors that you have captured and corrected, making sure you do not include PHI-sensitive references in your examples.

3. To help with this important effort, please encourage others within our industry and the doctors for whom you provide documentation services to submit supportive comments to the Committee. It would be very powerful for the HIT Policy Committee to hear from doctors who want certified EHR systems to include a dictation-transcription option and to allow for uniformly formatted and coded narrative reports.

4. When you submit your comments, please send a copy to staff member Greg Doggett at gdoggett@ahdionline.org. He will make sure your Congressional District’s Representative and your state’s two Senators receive a copy of your comments. (Be sure to provide Greg with your mailing address for the purpose of identifying your Representative.) It is critical that as many as decision-makers as possible hear our message.

If you have any questions, please contact Greg at gdoggett@ahdionline.org or 703-663-8379. Thank you in advance for taking time out of your busy schedules to aid this important effort.

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