For instance, the organization is concerned that a provision to have ONC-Authorized Certification Bodies incorporate I.T. safety in post-market surveillance of certified electronic health records technology is too broad and the ACBs lack core competencies on safety.
HIMSS further asserts that ONC already expects to leverage patient safety organizations’ common reporting system, and a common format that the Agency for Healthcare Research and Quality has developed. “We note that an ACB appendage for reporting may create an unnecessary level of complexity due to the potential for generating unfiltered reports in the absence of an analytic or response mechanism that fits into the overall reporting system.”
Unlike some commenters, HIMSS does not take a stand on the issue of creating a national patient identification system, but notes that it has asked Congress to direct a study of the issues and best approaches to identify an appropriate national patient data matching strategy.
HIMSS also calls a proposed requirement for a safety risk assessment as part of meaningful use a premature step in lieu of standards, and it may be burdensome to providers. The complete comment letter is available here.