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Health IT Feedback Form


Request for NACCHO Member Input on "Meaningful Use" of Electronic Health Records Now Closed

NACCHO thanks its members for helping submit comments to the Center for Medicaid and Medicare Services (CMS) about the meaningful use of electronic health record (EHR) technology.

The CMS EHR incentive program will provide payments to eligible professionals (EPs) and eligible hospitals participating in Medicare and Medicaid programs that adopt and meaningfully use certified EHR technology, which may include some local health departments (LHDs).

Congress specified three types of requirements for meaningful use:

  1. Use of certified EHR technology in a meaningful manner (for example, electronic prescribing);
  2. That the certified EHR technology is connected in a manner that provides for the electronic exchange of health information to improve the quality of care; and
  3. That in using certified EHR technology, the provider submits to the Secretary information on clinical quality measures and such other measures selected by the Secretary.

Your LHD will be affected by all three elements in this program, even if you do not provide comprehensive primary care. For example, EPs and hospitals will be required to develop the capability to electronically exchange (send and receive) data with public health.

NACCHO''s submitted recommendations on meaningful use to CMS.  

First NameLast NameAgency / OrganizationCommentsDate sort descending
Bloomington (MN) Division of Public Health
Thanks to NACCHO for organizing the response to this huge effort!

My first comment pertain to the collection,submission and sharing of population health data.  My concern is being able to retrieve the data or have data reports available to local jurisdictions in order to better assess and develop plans to improve the health of the populations we serve.  We have had the experience in MN of having information collected by the Minnesota Department of Human Services be put into a "data wharehouse" - never to be seen again!  If there is not a plan at the outset on how to collect and share the population health data, then I'm not hopeful the information will ever make will it to the local level (city, county).

My second comment pertains to other program data that could be shared, besides those mentioned by Diane Thornson - Breast and cervical cancer screening data (Pap smear and mammogram results)and data collected in the SAGE Plus program (height, weight, blood glucose, total cholesterol, HDL, LDL, triglycerides, and blood pressures). 
Dakota County Public Health, MN
I support NACCHO's general comments: In Public Health, nurses work as independent practitioners providing a wide variety of preventive services. There is no mechanism for local public health to receive incentives that could support the development and enhancement of electronic data exchange. PH is expected to be recipients of data, which is good, yet there is no financial support for infrastructure development. In order for PH to accept information, there has to be a HIT support plan for PH. And it will be critical to support bidirectional exchange of information, so that public health can send and receive information from clinics and other health providers.
Public Health continues to be challenged by lack of data about the health of the community being served. Access to  data about documented health conditions will allow Public Health to plan an intervention strategy that will respond to the needs of the community.
Improve care coordination: Many local public health departments provide health care services to incarcerated individuals in local jails. Capability to exhange clinical information with community clinics and hospitals is key to providing quality care and discharge planning.
Washington State Association of Local Public Health Officials
Overall, NACCHO's comments are good. 

Stage 1 Criteria for Meaningful Use: Other demographic information might include education, HH income, and family size, also areas for identifying disparities. Prescribed medicine poisoning is an increasing issue throughout the country and could be included in the population health perspective, along with smoking and BMI. Information obtained during a provider visit for injuries could include helmet, child car seat, and seat belt use. Also, useful information from a population health perspective.

2e Request for Public Comment: The mechanism to share health data may be different than an alerting system.  Definitely desired, but may be different.  Diane Thorson's comments are good examples of program data sharing.
Washington County Public Health & Environment
We are one of several LHDs in Minnesota who provide clinical care to county jail inmates. Only a few of the jails in the state have any form of electronic health record system. We are totally paper driven and the ability to exchange health information will not happen unless there is a substantial investment of local dollars to purchase a system or other sources of funding. My comments below are from the provider viewpoint which provides medical care to an underserved population.

Eligible Provider - Our medical care is primarily provided by a Physician Assistant, Advanced Practice Registered Nurse, and an occasional physician. Currently we cannot bill Medicaid for these services but this may change in the future. We recommend that the EP definition be expanded to these providers at a minimum.

Electronic prescriptions - In Minnesota there is a state law requiring all health care providers to implement e-prescribing by 2011. We are also required to meet this mandate in the county jail. We are looking to our pharmacy providers to assist in providing the system to do that but we are not sure the system they will provide will meet the "certified EHR" requirements.

Sending reminders - Our patients are sent to a local hospital for treatment, but I don''t think it would be necessary for the hospital to send reminders to those patients if they continue to be incarcerated. Would this requirement apply to other hospital patients released to skilled nursing facilities or other institutions?

Check insurance eligibility - This requires that the private payers have an electronic access to eligibility information and public health has the capability to receive the information electronically. Most often we have to make a telephone call to the payer to find out eligibility information and record ourselves.

Engage Patients - Because we are paper-based many of these requirements cannot be met until we have the funding necessary to purchase a system. We also have to follow state Corrections laws and rules regarding the health care services and records of jail inmates.

Improve Care Coordination - We need to be able to exchange information with clinics, labs, radiology providers, hospitals, and pharmacies as our patients may see these types of providers during their incarceration. As stated earlier, we need to have a system that can electronically accept that information so we are not ready to participate in any kind of test.

Population Health - As stated earlier, this is a very medically underserved population. It would be very helpful to have health status information about this population and find ways to reach out to and serve them outside of the jail setting. Population health data on this group could be used to establish public policy on health care access and prevention work.

Hamilton County Public Health-Ohio
Regarding "care goals" under the criteria for meaningful use entitled "communicate with public health", there needs to be two-way commuication between public health and health care professionals and vice-versa.  There should be a means for local public health agencies to alert local physicians, hositals, etc on communicable diseases circulating regionally.  These local alerts should assist health care professionals in their day to day practices.

Although difficult to ascertain, patients with environmental/occupational related illnesses should be captured in the EHR and communicated between local public health and health care professionals. Often, local public health agencies have environmental health data that could be used to assist in the prevention of various illnesses. 
Otter Tail County Public Health
I would like to provide examples of clinical data that would be helpful to be able to communicate between provider systems using an EHR.

WIC could share hemoglobin/hematocrit information, height and weight with clinicians to avoid duplicate testing.

Lead testing results could be shared between clinicians and public health to allow for the follow-up and avoid duplicate testing;

Vaccines administered in any setting would be valuable to access by all providers to avoid duplicate vaccines being administered or missed opportunities.

Clinical testing for refugee health exams need to be transmitted to local and state agencies.

Clinic testing and prescriptions for tuberculosis diagnosis and treatment need to be transmitted from clinicians to local and state public health agencies.

Reportable disease information should be transmitted between agencies.

Persons receive case management services by public health nurses.  The clinical lab testing and procedures as well as prescriptions information needs to be shared across agencies.  For example we must document mammograms, preventive health exams, colonoscopy, glycosolated hemoglobin, Vitamin D, Calcium, and aspirin therapy.

Hope these examples of data we work with every day will be helpful to address the meaningful use requirements. 

We currently bill medicare for flu vaccines and bill medicaid for numerous services.  Local public health agencies should be able to receive payment for EHR as a part of any billing submitted.

Marion County Health Dept. Indianapolis, IN
In general, I think the drafted comments are very good.  Here some specific comments:

· About 40% of a EP’s incentive amount comes in the 1st year (I.B.1.d, ~p. 1910), apparently purely based on the PE’s attestation that the PE has achieved the measures.  How will they avoid giving Yr1 incentives to providers already at Yr1 level, who are supposed to start with the Yr2 goals (I.B.1.d)?

· Improve coordination of care – Exchange key data.  NACCHO should strongly support this.  It is through this doorway that public health is likely to get better data, and to increase its value to clinicians by providing information.  That last bullet in this section (on the top of page 8) is important for similar reasons.

· Improve population and public health – They might add “capability to receive immunization data from an external immunization registry."  We need to create more onus on public health to do information exchange, and there may now be funding to support it.
Erie County Department of Health
For the goal:"Provide patients and families with timely access to data, knowledge, and tools to make informed decisions and to manage their health" steps must be taken to ensure that confidential adolescent health services, especially those for which minors have the right to consent in their state, are maintained confidential from other family members or health care providers if the adolescent does not want specific health information disclosed, such as sexcually transmitted diseases testing.
Houston Department of Health and Human Services (HDHHS)
Improve population and Public Health

Early event detection has been established as a priority for public health preparedness. By advancing EHR and HIE adoption and meaningful use in the greater Houston area, will substantially increase the capabilities of the existing early event detection system at HDHHS.

There are over 90 hospitals and 15,000 physicians in Houston metropolitan area.  The deployment of the service area HIE will efficiently populate a centralized public health data repository which can support a broad range of public health practice ranging from infectious disease case investigation, immunization, chronic disease, and environmental health surveillance. 

The HIE will support bi-directional communication, securely receiving public health information from regional providers and delivering public health alerts and information to providers and stakeholders with appropriate access controls.  The HIE will facilitate interoperability using standardized data formats and vocabularies as well as messaging standards to bridge providers’ certified EHR systems across the Houston area and LHDs implementation of public health information system.