EMR/EHR MUST go forward, but not until safeguards are in place

ANY EMR/EHR (electronic medical and/or health record) system is going to be expensive to deploy, and more thought and planning has to go into it prior to deployment.

To simply require medical professionals and service providers to adopt the use of technology without establishing proper safeguards and uniform methods of capturing and managing the content serves no purpose, and will ultimately result in a need for conversion, migration, and recovery that will be expensive and time consuming.

There is a lack of openness to the 'standards' being developed to establish the requirements for collection and control of this data, primarily because they are being driven by the largest players in the field (vendors selling what they insist on referring to as 'solutions') to the management of the data.

There needs to be input from a wider audience and the Standards, if they are TRULY going to be Standards in the ANSI/ISO/IEEE sense need to follow the criteria for development that encourages participation from a broader audience that will result in a consensus based set of documents that others can also work with, NOT just the firms who are able to "pay to play".

We also need to encourage the vendors to move away from their proprietary formats for data collection, and go towards more open formats to ensure long term persistent access to the information and to discourage the potential for loss of information as companies are bought and sold, and also to eliminate, or minimize, the need for conversion and migration of large volumes of data to allow for continued access as existing formats become obsolete.

And the largest issue still is PRIVACY and access controls. In the current model, there is a lack of this, irrespective of the language in HIPAA and the widespread volume of State Privacy Laws. There are no provisions to ensure only those who have a right to view or a need to know have access, and there is no current provision for a patient to have any say in this process.

Anyone who followed the events around Hurricanes Katrina and Rita will recall that it was the DHHS (Department of Health and Human Sevices) who lowered the standards for privacy protection and said they would NOT enforce the HIPAA (Health Insurance Portability and Accountability Act) requirements when they required all major pharmacies in the Gulf Coast region to provide open access to their prescription records in an attempt to share information. The most ludicrous comment made was they would sort the records out and return them to the providers "once things returned to normal in the region"... it's been almost 3-1/2 years and things STILL haven't returned to normal!

I fully support an eventual move to an EMR/EHR system that is preferably regional in nature that may permit a National linkage in times of need, but not until proper safeguards are in place.

Deployment and building of an infrastructure, along with ongoing support, will be extremely costly ... I personally don't think the existing estimates even brush the surface. But I'd encourage everyone to read the CREW report (Citizens for Responsibility and Ethics in Washington) on Electronic Recordkeeping in the Federal Government before they buy into the concept that the DHHS or any other Federal Agency should be controlling this program!!

Larry Medina