On May 2, 2016 Peter Basch, MD, MACP, Chair, Medical Informatics Committee, American College of Physicians (ACP) submitted ACP’s comments on the ONC Health IT Certification Program to Dr. Karen DeSalvo, Acting Assistant Secretary for Health, National Coordinator for Health Information Technology, U.S. Department of Health and Human Services.
ACP is the largest medical specialty society and the second-largest physician membership organization in the United States. ACP members include 143,000 internal medicine
physicians (internists), related subspecialists, and medical students. Internal medicine
physicians are specialists who apply scientific knowledge and clinical expertise to the diagnosis, treatment, and compassionate care of adults across the spectrum from health to complex illness.
In general, ACP stressed support of ONC’s proposals to initiate a direct review process of
software certified under the ONC Health IT Certification Program stating:
“there is an evident need for oversight of health IT for purposes of patient safety and effectiveness of quality care.”
ACP also expressed concern that the scope under which ONC would initiate the direct review is:
“…too broad and encompasses scenarios that fall outside the published requirements for electronic health record (EHR) certification.”
“Currently, the certification process consists of a series of fully specified tests that check for the presence or absence of functional criteria that are also specified in current regulation. This proposed rule would hold EHR vendors liable for functionality that is not specified anywhere in regulation, and would provide no useful guidance to vendors in advance of receiving a complaint.”