The Alliance for Nursing Informatics (ANI), as a unified voice representing more than 5000 nurse informaticists and 25 distinct nursing informatics groups in the United States, has issued responses to the Department of Health and Human Services on Medicare and Medicaid Programs: Electronic Health Record Incentive Program (document ID CMS-2009-0117-0002) and the Health Information Technology: Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology (document ID HHS-OS-2010-0001-0002).
The ANI Responses identified the following key considerations:
1. Ensure there is ample emphasis on the development of cognitive support to promote optimal clinician decisions.
2. Expand the definition of "meaningful user" to encompass support of all healthcare professionals in an integrated healthcare community including nurses (RNs), advance practice nurses (APRNs), and other clinicians as well as expanding sites to include patient-centered care delivered by interdisciplinary teams.
3. Consider industry trends, research, and experience in adequately identifying criteria for meaningful use to improve quality, safety, and efficiency and reduce health disparities.
4. Enhance programs and funding availability for the integration of informatics competencies and patient education offerings to effectively design and implement systems to support meaningful use of patient-centered EHRs.
5. Recognize the vital role of nursing practice as nurses are integral to improved care coordination.
6. Expand the sharing of data from multiple sources to improve population and public health to ensure adequate privacy and security protections for personal health information.
7. Reduce the number of criteria for certification to focus on integration of requirements to support efforts to improve health and safety.
The ANI's "NPRM Meaningful Use" full response is available online at http://www.himss.org/handouts/ANIResponsetoNPRMEHRIncentiveProgram-MeaningfulUse.
The IFR Standards, Implementation Specifications, and Certification Criteria response is available online at http://www.himss.org/handouts/ANIResponsetoIFRCertificationCriteriaFINAL.pdf.