Cchit & The Onc Ifr - Odds & Ends

As CCHIT published its comments to the ONC IFR, I took some other await at the Interim Final Rules in addition to I must acknowledge CCHIT is making some real skilful points. Read the CCHIT comments here.

Here are a few other odds in addition to ends that I believe volition drive problems. I don't quite sympathize why definitions couldn't bring been tightened downward a fleck to a greater extent than prior to publication. These are pretty simple things.

Medications & CPOE - Tangled Up

For ambulatory providers Medications are addressed inwards iv dissimilar criteria:
170.302(a) - Drug-drug, drug-allergy, drug-formulary checks.
170.302(c) - Maintain active medication list.
170.304(a) - Computerized provider guild entry. Enable a user to electronically record, store, retrieve, in addition to manage..... (1) Medications;(2) Laboratory;(3) Radiology/imaging; and(4) Provider referrals
170.304(b) - Electronically telephone commutation prescription information

Theoretically, purchasing a CPOE module in addition to ane of the available ePrescribers, similar Dr. First for example, should satisfy all iv criteria. However, the CPOE module cannot obtain certification for 170.304(a) without managing Med lists, which the ePrescriber already does in addition to must do. So either Dr. First starts managing Lab orders, or Lab guild modules origin managing prescriptions, or Dr. First in addition to the Lab guild vendor require to apply for certification together every bit ane product.

Suggested solution: Remove Medications management from CPOE.


CPOE - No Standards

For ambulatory EHR modules CPOE is defined every bit follows
170.304(a) - Computerized provider guild entry. Enable a user to electronically record, store, retrieve, in addition to manage, at a minimum, the next guild types:
(1) Medications;
(2) Laboratory;
(3) Radiology/imaging; and
(4) Provider referrals.

There is no specification of whatsoever standards to survive used for such recording of orders. This volition homecoming CPOE modules, certifying nether this premise, useless for electronic orders downward the road. I justice buyers require to beware!

Suggested solution: Require that Lab in addition to Radiology orders incorporate the HL7 required fields for each type of test. Medications, every bit mentioned above, should survive dealt amongst separately.

Smoking Status - What is that all about?

170.302(f) - Smoking status. Enable a user to electronically record, modify, in addition to remember the smoking condition of a patient. Smoking condition types must include: electrical flow smoker, one-time smoker, or never smoked.

Is anybody envisioning a standalone module that records in addition to displays ane item? What would a vendor of such module introduce for certification? Influenza A virus subtype H5N1 unmarried covert amongst 3 checkboxes in addition to an interface to post the information exceptional somewhere, or a database amongst 2 columns (one for patient identifier in addition to ane for smoking status)?

Suggested solution: If the insurance manufacture is hell bent to bring physicians tape this cryptic in addition to clinically lacking information point, it should survive added to 170.302(e) - Record in addition to nautical chart vital signs. This is a temporary solution, in addition to non a real skilful one, until Meaningful Use requires recording of other History items.

Regarding the EHR Module concept inwards general, the Definition that a Module is anything that satisfies at to the lowest degree ane criteria doesn't brand feel to me. If nosotros are going to certify Modules, in addition to nosotros should, they require to survive defined inwards a to a greater extent than sensible manner. When I mean value of an EHR Module, I envision an ePrescriber, or a Registry, non a Smoking Status Recorder.

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