Tara Turjillo-CO

With regard to the proposed rule on the Electronic Health Record Incentive Program, we offer the following comments on the proposed recommendations for care goals: Your recommendation: Implement drug-drug, drug-allergy, drug-formulary checks. - Additionally, implementation of periodic drug re-evaluation should occur, particularly for children with ongoing prescriptions related to physical and behavioral health. Your recommendation: Record smoking status for patients 13 years old or older. - This should be changed to 10 years old and older, as lack of requirement to ask this question of children under age 13 could miss an opportunity for children ages 10-13 to be identified. Additionally, this should also be changed to include use of any tobacco product, as students are now often choosing chew tobacco over cigarettes due to its ease of concealment. Finally, the smoking status of a child’s parent for all children ages 0-18 should be recorded as second-hand smoke is equally dangerous to the growth and development of a child. Your recommendation: Record the following demographics: preferred language, insurance type, gender, race and ethnicity, date of birth, and date and cause of death in the event of mortality. We are interested in public comments on how States and hospitals could work together to facilitate linkage between the EHR and the full birth and death certificate information that States currently require hospitals to collect. - CMS could require that for every child born, the hospital/EP must begin an EHR and that the hospital/EP and the EHR automatically interface with the state’s vital statistics records department, not only for the purposes of communicating birth and death information, but also for communicating disaggregated population health data. This could be done via a regular batch reporting, through a secure electronic interface or through a third-party data exchange entity. At a minimum, EHRs should be required to demonstrate a capability to provide socioeconomic health surveillance with regard to the ability for public health agencies to determine if clients in specific geographic areas are experiencing higher or more acute health conditions. Your recommendation: Record the following demographics: preferred language, insurance type, gender, race and ethnicity, and date of birth. - Income level and geographic location as social determinants of health are just as important as race and ethnicity for the purposes of fully understanding the impact of the patient’s environment in diagnosis, care management and health maintenance. - Your recommendation: Generate and transmit permissible prescriptions electronically (eRx). - The recommendation is fine, although rural EPs working with local pharmacies who are unable to accept e-prescriptions should be granted a waiver from the 75 percent of prescription transmittals. Additional recommendations for consideration: For children and pregnant women, record any social/behavioral health screenings and outcomes as they relate directly to a child’s overall development. Record referrals to relevant community service programs, for example, community smoking cessation programs or parent support groups. For children 0-18 additional information should be recorded including information about the child’s family and home health. For example, parents smoking, physical activity, food insecurity, physical or emotional trauma or parental concerns. For Year 3, the proposed rule expresses intent to expand to include additional measures on oral health. However, for years 1 and 2, it should be required of all participating providers that they record at least general information patients provide on known health issues and concerns like, untreated dental decay or abcesses which could affect overall health. Beginning at birth, record the presence of birth-related issues including birth defects, low-birthweight and prematurity. Thank you for the opportunity to provide comments. Please do not hesitate to contact me if I can provide further information.