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Monday, February 4, 2013

Please comment: Patient Safety Action & Surveillance Plan being requested by ONC for HIT


"Health IT and Patient Safety

On December 21, 2012, the Office of the National Coordinator for Health Information Technology (ONC) issued the Health IT Patient Safety Action and Surveillance Planfor public comment.
The Department of Health and Human Services (HHS) is taking actions on health ITand patient safety. HHS is calling on the private sector to take actions as well. To address health IT and patient safety, a shared responsibility among the government, health IT industry, patient safety organizations and health care providers is needed to support a culture of safety.
The Health IT Safety Plan may be viewed here. All public comments must be submitted by February 4, 2013, 11:59 pm EST to Based on the public input, ONC will publish the final Health IT Safety Plan."

DID YOU KNOW YOU HAVE LESS THAN 24 HOURS TO COMMENT? : Patient Safety Action/Surveillance Plan for Public Comment that is being requested by Office of the National Coordinator for Health Information Technology. 

PLEASE email comment to

Below is the letter that the great folks at TMIT put together and I added my own comments throughout; Sort of like a public comment MAD LIB.  Please feel free to do the same.  TMIT has been working on this issue for years.  You know TMIT, the non-profit that built so more patients could speak out at conferences.  Just sayin'

To the ONC Reviewers for Public Comments on the Health IT Patient Safety Action & Surveillance:


So glad to see you are tackling this thorny issue!!!

I thought I would throw my 2 cents in and provide comments and suggestions for improvement of the Office of the National Coordinator for Health IT Patient Safety Action & Surveillance Plan issued on Dec. 21, 2012, for public comment.

As you well know, I am very concerned about patient safety and HIT risks to my family and the community.

I am actively involved in patient safety and have been concerned about the safety testing of electronic health records (EHR) and computerized prescriber order entry (CPOE).

REQUEST: I would like to recommend that ONC certifiers work with a collaborative team and innovation that is already in place for post-deployment performance surveillance of Electronic Health Record and Computerized Prescriber Order Entry systems: the EHR-CPOE Flight Simulator, developed and made available by TMIT a 501c3 not for profit medical research organization.  TMIT has led patient safety initiatives for 30 years and has collaborated with multiple government agencies.

I have worked with TMIT on and have been one of their patient advisors for 2 years.  They constantly work to improve patient safety in all aspects including in HIT.

This tool has been successfully used to examine hospital safety problems in EHR-CPOE, is scalable, reliable, and is saving lives and money and is currently in use by Leapfrog.

Please do not waste any more time starting over in this area.  Please build from a strong foundation by a trusted source in this field.  I for one have gotten very tired of watching safety goals delayed for years while government grantees redesign the wheel.

This EHR-CPOE Flight Simulator has been used to evaluate hundreds of inpatient and ambulatory EHR systems in the United States and piloted in the United Kingdom. TMIT proposes to work with ONC-Authorized Accrediting Bodies, PSOs, and QIOs to further refine the simulators, and to have monthly webinars to educate hospitals on how to obtain and adopt this useful, already proven tool.

An article just released that describes the history of the simulator, data regarding hospital leaders confirming great risk in health information technology, and the global strategy that a team is taking to address this problem now. Entitled SAFE USE OF ELECTRONIC HEALTH RECORDS AND HEALTH INFORMATION TECHNOLOGY SYSTEMS: TRUST BUT VERIFY it is in the Journal of Patient safety, and it is available at:
Thank you for considering having agencies work with the existing team on the TMIT EHR-CPOE Simulator. Use of this tool would be in keeping with the original directive of the ONC, which is to employ the expertise and talent we already have to solve the problems inherent in current EHR and CPOE systems. Thank you for giving us the opportunity to comment on this important issue. 

Thank you for your time and your consideration of looking at this tool, as TMIT has kept patients in the communication loop since inception, and we were not a tacked on as an after-thought.


Regina Holliday

Patient Activist

1 comment:

  1. What a great post. I have been looking up information on electronic health records for my medical billing class. I have seen so many blog posts about this subject. I have seen both sides (the pro's and the con's). Thanks so much for your post as well. I found it to be an informative read.