June 26, RE: HIT Policy Committee Meaningful Use Comments. Dear Dr. Blumenthal:

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1 June 26, 2009 David Blumenthal, MD, MPP National Coordinator Office of the National Coordinator for Health Information Technology 200 Independence Avenue, SW Suite 729D Washington, DC RE: HIT Policy Committee Meaningful Use Comments Dear Dr. Blumenthal: On behalf of the American Physical Therapy Association s (APTA) 73,000 member physical therapists, physical therapist assistants, and students of physical therapy, we appreciate the opportunity to submit comments to the Office of the National Coordinator for Health Information Technology (ONCHIT) in response to the notice and request for comments published in the Federal Register on June 16, 2009 for Meaningful Use. APTA is committed to advancing the safety and quality of healthcare through health information technology (HIT) innovation and we are eager to work with the ONCHIT as it develops a definition of and criteria for Meaningful Use as mandated in the American Reinvestment and Recovery Act of 2009 (ARRA). Physical therapists practice in a number of settings, are integral members of the health care community and offer a wealth of expertise that could be valuable to the ONCHIT and HIT Policy Committee as they work to create an interoperable national health information network and implement the provisions of the ARRA. Thus far, the focus of the HIT discussions has been on physicians and hospitals. We strongly urge ONCHIT and the HIT Policy Committee to broaden their perspectives and recognize the vital role of other health care professionals across the continuum of care in the development, implementation and Meaningful Use of HIT. Therefore, we strongly recommend that ONCHIT ensures that goals, objectives, and measures applicable to physical therapists and other rehabilitation providers are included in the criteria for Meaningful Use. APTA has made several strides over the last eight years to promote the use of HIT, and we are continually enhancing our services to advance the delivery of physical therapy and to effectively measure patient outcomes. These efforts include the inclusion of HIT educational tools on the APTA website, collaborating with internal and external stakeholders on HIT issues, and partnering with Cedaron Medical, Inc to develop an electronic health record (EHR), called APTA CONNECT, which incorporates a National Outcomes Database for physical therapy. The EHR is specifically designed for physical

2 therapists and has been an approved registry for the past 2 years. The National Outcomes Database will consist of aggregated data from APTA CONNECT and other EHRs and will be used by APTA and independent researchers to answer questions important to improve the care of individuals receiving physical therapy services. Through the development of these projects, APTA and our members have gained a unique knowledge base that would be valuable to the development of a definition of Meaningful Use and the widespread adoption of HIT within healthcare. APTA is actively involved in other initiatives that warrant appropriate HIT adoption. Examples include Medicare s Physician Quality Reporting Initiative (PQRI) and Provider Value-Based Purchasing (PVBP) projects that have specific components related to EHRs; working with CMS and its contractors on payment reform for therapy services; preparing our members for the transition to ICD-10 and the implementation of the revised Health Insurance Portability and Accountability Act (HIPAA) provisions. In addition, we are planning advancement to our EHR to increase clinical decision-making assists. Suffice it to say that there are currently many projects underway that would benefit from a comprehensive and coordinated health information technology system that would include physical therapy and rehabilitation. In order to response to the request for comments, APTA submits our general Recommendations for Meaningful Use and specific feedback regarding the Meaningful Use Matrix that was presented at the June 16, 2009 meeting. APTA Recommendations for Meaningful Use 1. Improve the outcomes of care for individuals and the health status of the American population by ensuring that the work of any national health information system is based on quality measurement and outcomes and contributes to a National Healthcare Database. 2. Develop metrics that allow for a broad range of providers to participate that are easy to report, adaptable to various provider characteristics, and auditable. 3. Provide clinical decision making support through EHRs to ensure Meaningful Use. 4. Ensure EHRs can capture the variety of clinical information relevant to both individual patient and setting for optimal safety and quality of care. 5. Ensure continuity of care through collaboration of all healthcare providers though their ability to communicate accurately and efficiently. Recommendations Regarding HIT Policy s Meaningful Use Matrix APTA appreciates the diligent work of the Meaningful Use Workgroup in its effort to develop a vision for what HIT may achieve by However, we want to ensure that the vision and matrix incorporate a broader perspective. Specifically, that the elements Page 2 of 5

3 represent all health care providers that use HIT, including physical therapists. We also want to ensure that the approach outlined in the Meaningful Use Matrix does not increase provider burden and expense. APTA strongly recommends that physical therapists collaborate with ONCHIT to develop the goals, objectives and measures that would best describe the Meaningful Use of HIT for rehabilitation providers. A vision for what HIT can achieve through Meaningful Use should be collaborative and inclusive of a variety of clinical specialties. While APTA supports several of the goals outlined by the Meaningful Use Workgroup, we feel that these goals should be more inclusive of the variety of clinical specialties that may be involved in a patient s care and a critical link in the collaboration and coordination of care. In discussions of Meaningful Use, it is often mentioned that an electronic health record (EHR) should incorporate e-prescribing capabilities. This is an important element of Meaningful Use and many of the current goals and objectives are relevant for physical therapist practice. However for physical therapists and other health care professionals currently limited in their ability to prescribe medications, laboratory tests, or imaging procedures in many jurisdictions, some of the details related to e- prescribing are not relevant and burdensome. Current criteria set forth by certifying organizations, such as CCHIT, prevent products designed for use by non-physician practitioners, such as physical therapists, from being certified. Therefore, as the workgroup moves forward with Meaningful Use criteria, we want to ensure that EHRs that are specifically designed for the needs of all patients receiving care from an array of health care professionals are recognized by CCHIT and other certifying bodies. Goals for Meaningful Use should be inclusive of more individuals. As the Committee sets forth with its work, it should consider the special health care challenges faced by vulnerable populations, such as children, persons with disabilities and individuals of various socio-economic, gender, ethnic, and racial backgrounds. Consider how a phased approach to implementation of Meaningful Use would affect the provider. Meaningful Use, as outlined by the workgroup, would establish different criteria for Meaningful Use in 2011, 2013, and The criteria build upon each other at every step of this timeline. While we support the phased approach, there is concern that those providers who adopt systems in 2011, when there are more basic or minimal criteria, would incur additional costs, either through software upgrades or re-certification requirements, than those who wait to adopt in 2013, 2015, or later. The workgroup should recommend strategies to avoid excess cost and burden associated with a phased implementation. Additionally, the workgroup should provide additional incentives to aid all healthcare providers in HIT implementation by the availability of grants applicable to all providers and by decreasing unnecessary and burdensome requirements. Many of the measures the workgroup has suggested to quantify for Meaningful Use are not inclusive of health care professionals such as physical therapists. Page 3 of 5

4 With regards to the current Meaningful Use Matrix, APTA supports the intent to include quality measures as necessary capabilities of meaningful HIT. As previously stated, APTA has developed and will continue to develop appropriate measures for physical therapist practice in coordination with CMS s PQRI and other initiatives. However, the appropriate and necessary measure(s) may vary significantly by patient need and professional scope of practice. We recommend language which ensures the intent of quality measure inclusion but that the listing of applicable measures be broadened to be more inclusive. Measure of great significant to physical therapists might include for example the risk and prevention of falls and participation in physical activity and activities of daily life. An educational strategy that takes into consideration the varying degrees of familiarity and current use by health care providers should be clearly established before the final criteria for Meaningful Use can be established. As the workgroup moves forward with its work on Meaningful Use, it is important to ensure that time and resources are spent developing an educational strategy to help providers understand what is being asked of them. The workgroup may want to consider expanding the timeline for adoption beyond 2015 to provide further guidance and support as providers incorporate EHR into practice. Consider the role of certifying entities. Presently, certifying entities utilize standards that unduly disregard health care providers that are not physicians. As already mentioned in these comments, APTA is very concerned that physical therapists and other providers using an EHR without e- prescribing capability will be prevented from receiving certification. The importance of ensuring that the entity that certifies EHRs account for all providers of health care is paramount to widespread use and implementation of HIT. Additionally, APTA recommends that the workgroup and ONCHIT consider the large volume of requests they will receive to certify HIT products. An adequate number of certifying bodies should be available in order to meet the demand and reduce delays in certification. This will also allow providers to avail themselves to the incentives being offered in a timely fashion. Consider aspects that focus on non-clinical factors We agree with many HIT Policy Committee members that expressed concern that the Meaningful Use goals did not focus strongly enough on non-clinical factors including patient empowerment, patient needs, privacy, technical possibilities and capabilities, and development of health care efficiencies. Page 4 of 5

5 Conclusion In conclusion, it is vitally important that the adoption of health information technology is approached comprehensively, including valid patient assessment tools, clearly identified health outcomes, interventions based on sound science and evidence, recognition that individuals with the same condition often present differently, and encompass a wide range of health care providers in health information technology adoption plans. Too often discussions about health information technology are centered on physicians and hospitals only. The discussions need to focus on better performance by the health care provider and improved health outcomes to the person served, not simply adoption of HIT. We strongly urge ONCHIT to expand the scope and focus of their work and make it a priority to ensure the inclusion of all health care providers throughout the full spectrum of care. We look forward to working with the HHS and ONCHIT as it looks for opportunities to assist health care providers in the adoption and Meaningful Use of electronic medical records. Thank you for your consideration of our comments. R. Scott Ward, PT, PhD Page 5 of 5

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