Key ingredient missing from e-health records, advisers say

A federal advisory panel says EHR regulations should include doctors' narrative notes

The Health and Human Services Department might have missed an opportunity to include a requirement for physician progress notes to be collected within subsidized electronic health records (EHRs) in its recent proposed regulation, according to members of a federal advisory committee that met today.

HHS’ Health Information Technology Policy Committee convened to discuss possible missed opportunities, areas needing clarification and other gaps in the proposed rule, which was released on Dec. 30, 2009.

HHS’ proposed regulation sets terms for the distribution of at least $17 billion in economic stimulus law funding for certified EHR systems. It describes how physicians and hospitals can be eligible for the money if they become meaningful users of such systems. A separate interim final rule laid out the terms for certification and technical standards.

Both regulations were published in the Federal Register today after being previously released for discussion. The public has 60 days to comment.

Physician progress notes are generally narrative notes written by doctors to describe a patient’s concerns. Some doctors have been advocating for inclusion of such narratives within digital health records as a valuable tool for understanding and properly diagnosing a medical condition or injury. Typically, commercial digital record systems do not offer such a narrative, but instead allow doctors to check various boxes on a template to describe a patient’s condition.

In a recent survey of 17,000 doctors nationwide, 94 percent said including patient narratives is very important for EHRs, and 96 percent voiced concerns about losing valuable patient information without the narrative. The Dec. 31, 2009, survey was released by Nuance Communications Inc.

HHS’ lack of a provision ensuring capture of the physician narrative within certified digital health record systems could be one of the “missed opportunities” in the regulation, according to testimony presented by Paul Tang, co-chairman of the panel’s workgroup on meaningful use and chief medical information officer of the Palo Alto Medical Foundation, and George Hripcsak, workgroup co-chairman and bioinformatics professor at Columbia University.

HHS also apparently missed a chance to set up indicators within the rule regarding substitution of generic drugs, and for use of certain high-cost imaging tools for diagnosis, according to Tang and Hripcsak.

Other areas needing further clarification include specifying when digital medication records must be reconciled among providers, and how long digital records on patient medications, problem lists and allergies should be maintained, among other concerns, Tang and Hripcsak indicated in their testimony.

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