CDT supports the use of electronic health records (EHR) by health care providers and by patients to improve individual and population health. As the federal “Meaningful Use” incentive program to promote adoption and use of EHRs approaches its third and final phase, the ability of patients to view, download and transmit their own health information – granted in the final Stage 2 eligibility criteria – is increasingly taking center stage. As a result, strong privacy and security policies and technical safeguards are more important than ever.
The attached document contains the comments CDT submitted to the the Office of the National Coordinator for Health IT and its Health IT Policy Committee on the Request for Comment regarding the proposed Stage 3 criteria. Our comments are in the areas of view/download/transmit functionality; patient-generated health information; the ability to request an amendment through an online portal; EHR query capability; privacy and security, including identification, authentication and accounting of disclosures; patient identity matching; and consent management.