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My comments to the Proposed Rule EHR Incentive Program-Stage 2

05/07/2012
My comments to the Proposed Rule Medicare and Medicaid Programs: Electronic Health Record Incentive Program-Stage 2 (Document ID CMS-2012-0022-0001)  
Not my most eloquent writing.  Did in hurry to meet 5pm deadline.

Comment on Sec.170.314(a)(2) (Drug-drug, drug-allergy interaction checks) 
This section outlines to “recommended limiting the ability to make adjustments to an identified set of users or available as a system administrative function.”  For both Drug-Drug and Drug allergy interaction checking it is imperative that adjustment be made by providers.  With false positive alarms of these checks still being very high it is imperative that providers are able to customize these alert to their practice sites.
In a study of the high rate of over rides in allergy alerts, recommendations have been made to decrease the incidence of overrides in allergy alerts.  These recommendations have largely not been implemented in EHRs, causing the high override rates to remain. (Characteristics and Consequences of Drug Allergy Alert Overrides in a Computerized Physician Order Entry System. J Am Med Inform Assoc. 2004;11:482–491. DOI 10.1197/jamia.M1556)
Comment on Sec. 170.314(a)(17) (Inpatient setting only–electronic medication administration record) 
There continues to be a lack of serious evidence on the use of technology to confirm the ”5 rights” of medication administration.  The stated study (NEJM Medicine 362:1698-1707) realizes most of the benefit from an electronic medication record documentation and not the bar code scanning, or “5 right” checking itself. 
Until there is sufficient evidence of return on investment in terms of outcomes or reduction in medication errors, I would suggest that the requirement for “5 right” checking be eliminated and electronic medication administration records remain.

*** Sad Note ***
It is very disappointing that I could not identify myself in a list of health care providers as a pharmacist.  Nurses Aids was listed among many others.  No pharmacist listing.

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