Federal Strategic Plan to Reduce Health IT Disparities: Request for Comment

Request for Comment: Federal Strategic Plan to Reduce Health IT Disparities

Working to ensure all Americans benefit from health IT is one of the principles guiding the development and execution of the federal health IT strategy. The Federal Health IT Strategic Plan that was released for public comment on March 25, 2011, states that we will strive to:

Support health information technology (heath IT) benefits for all. All Americans should have equal access to quality health care. This includes the benefits conferred by health IT.: The government will endeavor to assure that underserved and at-risk individuals enjoy these benefits to the same extent as all other citizens.

For the past few months, the Health IT Disparities Workgroup — comprised of staff from agencies of the U.S. Department of Health and Human Services (HHS): with strategic and operational programs in health IT and co-chaired by the Office of the National Coordinator for Health Information Technology (ONC) and the Office of Minority Health (OMH) — has led a focused effort to further define the federal government’s strategies and tactics to reduce health IT disparities within underserved communities. The result of this process will reflect our commitment to do more to reduce health IT disparities.

The Health IT Disparities Workgroup is developing a federal plan to reduce health IT disparities.: A draft set of strategies/tactics — aligned with the five goals of the Federal Health IT Strategic Plan — is included below: We hope you will assist us by providing comments on the following questions:

  • What do you think of the draft strategies / tactics listed below?
  • What specific activities would you like to see the federal government take on to reduce health IT disparities?

Health information technologies — such as electronic health records (EHRs), telemedicine, mobile health, and electronic disease registries — have been identified as effective means of helping to deliver safe, effective, affordable health care services; coordinate care across providers and clinical settings; and provide critical population data that may catalyze further policy and delivery system innovations.

The growing adoption and meaningful use of health IT is even more critical within the context of underserved communities. Within both rural and urban underserved communities, access to primary and specialty health care resources can be limited. This scarcity in many instances contributes to reduced quality of health care and of health outcomes for people residing in these communities. Within underserved communities, the use of health IT has demonstrated it can improve health outcomes, both from an individual and community-/system-wide perspective.

Federal planning efforts focused at reducing health disparities, including The National Stakeholder’s Strategy and the HHS Action Plan to Reduce Racial and Ethnic Health Disparities, highlight the proliferation of meaningful use of health IT within underserved communities as a critical objective. This draft set of strategies/tactics (see below) for the federal plan to reduce health IT disparities aims to ensure that underserved communities realize the full benefits of health IT.

Goals of the Federal Health IT Strategic Plan

Goal I: Achieve Adoption and Information Exchange through Meaningful Use of Health IT

  1. Accelerate adoption of EHRs
  2. Facilitate information exchange to support meaningful use of EHRs
  3. Support health IT adoption and information exchange for public health and populations with unique needs

Objective A

  • Future HHS grant programs focusing upon the provision of EHRs, use of telemedicine/telehealth, mobile health, or services to enable the purchase and use of health IT should emphasize the importance and, whenever feasible, work toward optimizing the program’s total number of providers who practice within medically underserved areas (MUAs) as defined by the Health Resources and Services Administration (HRSA).
  • Recognize vendors who work extensively within underserved communities, as well as examine the concept of a “Public-Private Digital Parity Partnership,” wherein health IT vendors will pledge to work with a specific number of providers who practice within MUAs (as defined by HRSA). In exchange for offering these providers reduced health IT product and service purchasing rates, vendors who participate in this program will have access to assistance with identifying eligible providers within the MUAs, and a letter of support for health IT adoption and use from the National Health Information Technology (NHIT) Collaborative and/or other appropriate health IT minority advocacy organizations.
  • HHS will continue its collaboration with the U.S. Department of Agriculture (USDA). Specifically, the HHS Secretary’s Rural Health IT Task Force, especially HRSA and ONC, will continue to work with the (USDA) Rural Development, in accordance with the 2011 Memorandum of Understanding, to ensure that rural health care providers can use USDA grants and loans to support the acquisition of health IT infrastructure.:
  • HHS OPDIVS/STAFFDIVS will work collaboratively with the HHS OMH, as well as ONC’s Health Information Technology Resource Center (HITRC), to highlight practical, effective methods to achieve adoption and meaningful use of health IT by providers within underserved communities. These practical, effective methods will be published annually on a site and/or reference to be determined.: :
  • HHS will collaborate with workforce training programs to implement marketing and communication campaigns reaching underserved communities. The campaign elements will highlight reduced tuition through grants to qualified health care personnel within underserved communities that participate in community college or university health IT training programs. Health IT workforce training programs will also be made available to students who attend minority serving institutions, such as Hispanic Serving Institutions, Tribal Colleges and Universities, and Historically Black Colleges and Universities.
  • Work closely with White House Initiatives on Asian Americans and Pacific Islanders, Hispanic Excellence, and Historically Black Colleges and Universities to disseminate information on the meaningful use of health IT.
  • Effectively communicate to minority and underserved advocacy organizations, HBCUs, and health IT training programs in general the benefits and importance of achieving meaningful use, particularly the importance of health IT’s potential to reduce care disparities for underserved populations.
  • Partner with the National Medical Association , National Hispanic Medical Association , National Council of Asian & Pacific Islander Physicians , and other minority health care provider advocacy organizations to facilitate meaningful use continuing education: training programs.

Objective B

  • Through the State HIE Program identify providers and communities where exchange may not be possible and provide strategic plans for enabling exchange capabilities coordinated with State Medicaid Health Plans to leverage federal resources to specifically meet the needs of underserved communities.
  • Work closely with the Federal Communications Commission (FCC) to ensure that relevant FCC programs support the Administration’s health IT objectives. For example, continue the HHS Secretary’s Rural Health IT Task Force’s ongoing efforts to ensure that relevant FCC programs (e.g., the Rural Health Care Support Mechanism, the Connect America Fund) support the Administration’s health IT objectives.

Objective C

  • Provide leadership for health IT and data collection, tracking, and analysis of stratification of quality measures by race and ethnicity data as mandated in the Affordable Care Act.

Goal 2: Improve Care, Improve Population Health, and Reduce Health Care Costs through the Use of Health IT

  1. Support more sophisticated uses of EHRs and other health IT to improve health system performance
  2. Better manage care, efficiency, and population health through EHR-generated reporting measures
  3. Demonstrate health IT-enabled reform of payment structures, clinical practices, and population health management
  4. Support new approaches to the use of health IT in research, public and population health, and national health security

Objective B

  • OPDIVS/STAFFDIVS will identify quality, efficiency, and population health measures relevant to underserved communities, providers within these communities, including measures directly related to the adoption/meaningful use of health IT. These measures will be calculated on data stored on a distributed (interagency, shared-access) database, with the measure results made publicly available at appropriate levels of analysis (e.g., provider- and community-specific). The Health IT Disparities Workgroup will consult the HHS Data Council and work closely with AHRQ to select metrics correlating with adoption and meaningful use of health IT within underserved communities for purposes of publication in the annual AHRQ Health care Disparities Report.

Objective C

  • Align future HHS and non-HHS (VA, DoD, etc.) health IT and payment reform pilots and demonstrations/initiatives to include communities designated as MUAs.

Goal 3: Inspire Confidence and Trust in Health IT

  1. Protect confidentiality, integrity, and availability of health information
  2. Inform individuals of their rights and increase transparency regarding the uses of protected health information
  3. Improve safety and effectiveness of health IT

Objectives A, B, & C

  • Engage provider and patient advocacy groups to create and disseminate multi-lingual information to increase both providers’ and consumers’ understanding of how Health Insurance Portability and Accountability Act (HIPAA) and other laws and regulations are implemented to protect their private, confidential, and sensitive information.
  • Communicate to both consumer and provider advocacy groups representative of minorities that data is collected, used, and stored using safe, trustworthy technology, policies, and practices.

Goal 4: Empower Individuals with Health IT to Improve Their Health and the Health Care System

  1. Engage individuals with health IT
  2. Accelerate individual and caregiver access to their electronic health information in a format they can use and reuse
  3. Integrate patient-generated health information and consumer health IT with clinical applications to support patient-centered care

Objective A

  • Determine if the Culturally and Linguistically Appropriate Services (CLAS) Act and its National Standards must be adapted to encompass health messages delivered via mobile devices, and effect such adaptation if needed.
  • Educate consumers about the availability and value to them of personal health records (PHRs), cellular/mhealth, and other types of ehealth or consumer health IT applications. Funding OPDVIS/STAFFDIVS will include IHS, OMH, and other agencies. Interagency, interdisciplinary teams of experts will develop the program announcement(s) and participate in application review(s), ensuring adequate inclusion of providers and consumers within underserved communities.
  • Determine appropriate literacy levels and use innovative strategies to convey health IT information effectively at those literacy levels and in consumers’ preferred languages.
  • Prioritize the engagement of minority patient advocacy organizations as a two-way mechanism to inform inclusive strategies across health IT initiatives as well as identifying possible new initiatives.

Objective B

  • Locate and communicate best practices of consumer and caregiver access in the context of underserved communities; showcase nationally “community champions” of effective patient engagement and patient-centric health care.

Goal V: Achieve Rapid Learning and Technological Advancement

  1. Lead the creation of a learning health system to support quality, research, and public and population health
  2. Broaden the capacity of health IT through innovation and research

Objectives A & B

  • Current HHS Comparative Effectiveness Research objectives will be linked, when applicable, to HHS health IT grants and programmatic outcomes.
  • In developing strategies to advance and measure progress toward the National Quality Strategy, HHS will utilize EHR-based clinical quality datasets that include language, race, and ethnicity information.
  • ONC and OMH will create a charter for the HHS Health IT Disparities Workgroup, and this group will meet quarterly to update progress towards the strategic plan’s objectives.
  • The Workgroup will create an annual federal conference where HHS and other (e.g., VA, DoD) agencies will share and develop information and evidence of effective practices for federal supporting widespread achievement of meaningful use of health IT within underserved communities. To promote efficiency, this conference will be integrated or coincide with an existing HHS-supported national conference (e.g. AHRQ or ONC annual grantee meetings) already regularly attended by key participants.:

We want to hear from you. Please submit your comments below.

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35 Comments

  1. Sudhir says:

    Greetings

    The first thing I look for what is the what – what is it that needs the public comment. Even a long glance did not help me find it. I almost decided that the public period has closed, thanks to the similarly worded highlight on that page. Since I was interested in the content, I poked around for more than a minute before I understood the article.

    1. “We hope you will assist us by providing comments on the following questions” — These questions and the main content of this article are half way down the page.

    2. “What do you think of the draft strategies / tactics listed below?” —- Where are these stratigies and tactics? There are 3 paragraphs in plain text after this question. Then there are the highlighted goals.

    This presentation may not elicit as many responses as expected because its hard to understand what is being asked for.

  2. Lisa Eng says:

    Access – many of my chinese elderly are poor and do not have access to a computer to get to patient portals – and if they get to that point – the EMR’s are in English and not sensitive to low English proficiency.

    Additional time should be given to doctors that care for non-English or LEP – and reimbursement for the added skill and time it takes to care for them.

    for demographics – granular ethnicity and province/city of origin in China is significant – dialect preferred as well. Just listing “Asian” is not sufficient. and non-white – non -hispanic means nothing. Should be required to list English proficiency level that is self -identified by patient as well as preferred spoken language and written language. In order to garnish any useful information about population health – need to first figure out what population(s) ethnically patient belongs to. Many are of mixed race origin now as well. Some Chinese only speak Spanish (truly) – so culturally competent must separate ethnicity from language. Part of demographic information that is gotten (should be required in EMR’s and PM programs) is patient to register their email addresses, do they have access to computer readily – texting, etc. to gauge pt’s computer sophistication.

    I am president of the Association of Chinese American Physicians, and serve on MSSNY’s Committee to Eliminate Healthcare Disparities, on the Board of NYS Osteopathic Medical Society and am president elect of Kings County Medical Society – I have private practices in Manhattan Chinatown and Brooklyn Sunset park and serve a Chinese, Spanish and mixed European/Italian neighborhood.

  3. Amy says:

    It would be helpful to know the public comment period. Please clarify.

  4. Gretchen Rhedmon says:

    These look similar to the original goals but with a little more enthusiasm probably due to the impending Pres election. I would like to point out that health delivery disparities are not limited to geography. Grants need to be established that would enable the development of an HIE system, and the provision of eHRs, for the clinicians that serve the homeless population in metropolitan areas. This would help monitor immunization rates, syndromic surveillance, and chronic diseases among the displaced.

    There is also a population of “protected” individuals, ie abuse victims, that need access with very specific security.

    Thank you.

  5. Karith says:

    I am not sure what to comment about. As several have mentioned, the request is unclear. Please clarify. Thanks!

  6. Barry says:

    Barry Michaels

    I have been working with Cedric Woods, Director of the Institute for New England Native American Studies at UMASS Boston (617-287-5784) to develop a proposed concept for Native American outreach and support.

    While working to access Native Americans in Massachusetts, it became apparent that the Native American leadership was overwhelmed with pressing issues and seriously under-staffed in accessing and managing needed resources on behalf of their people. One promising access idea was to provide support to Native American leaders through a statewide 501(c)(3) nonprofit corporation having at least 51% Native American leaders on its board of directors whose purposes might be to:

    1. Serve as a focal point for improving Native American utilization of all available resources by tribal entities, organizations and self-identified Native Americans by collecting and sharing with their leaders available grant and contract opportunities;

    2. Prepare proposals for such funds as might benefit Massachusetts tribes and Native American organizations and individuals either in collaboration with, or in competition with, other Native American applicants;

    3. Develop Native American Memoranda of Agreements (MOU) with state agencies, service providers and/or educational institutions, etc;

    4. Provide data collection, and program management services or expertise to Native American recipients of State, Federal and charitable funds and services;

    5. Provide and coordinate Native American cultural sensitivity training for various service providers and State Agencies.

    This coalition concept was to provide staff to three urban Massachusetts communities (Boston, Worcester and Springfield) with a contract that could go through a non-profit corporation and be led by a:

    1. Native American Indian statewide Program Director and

    2. Three (3) Native American Indian Sub-state Program Coordin-
    ators (one in each urban area) who duties would include:

    a) Co-developing Memoranda of Understanding (MOU) with various
    State agencies and service provider organizations;

    b) Arranging for Native American cultural sensitivity and
    spiritual awareness training to service provider agencies;

    c) Resolve, ombudsman-like, disputes between Native American
    clients and their service providers; (this might become a function of the Massachusetts Commission on Native American Affairs)and

    d) Secure health provider service training for volunteer
    and/or paid community-based Native American Family
    Advisor/Advocates.

    One means to a successful MOU would be the willingness by State agencies and service providers to pay for the services of Native American Indian cultural experts who would:

    1) provide

    a) targeted case management and b) ombudsmen services on
    behalf of State Agencies and service provider agencies (In accord with Title VI of the U.S. Civil Rights that State agencies receiving Federal funds provide for non-discrimination in assuring access to services); and

    2) provide Native American Indian cultural sensitivity training
    for provider agency staff and contracted service providers.

    It would also be important to develop an State administrative rule that would recognize the 501(c)(3) Native American Leadership Corporation as being authorized to assist, in an ombudsman-like way that augments existing appeal remedies, and resolve service delivery problems or denials of service to off-reservation Native Americans.

    Native American Family Advisors/Advocates would be trained to:

    Develop trusted relationships with Native American individuals and their families to determine what family needs and interests might be served by mainstream service agencies or by other unique interventions, i.e., health/ jobs/education/ meals/ housing/ Transportation/ spirituality/ welfare/ mental health/ veterans affairs, etc. Provide approved services to various service providers that may request targeted case management aid (i.e., getting people to appointments/ help to understand and correctly follow medical orders and prescriptions interpret-tation/ assistance with service applications/, securing employ-ment, housing or education, etc.)

    Some Native Americans did not complete school, or even if they did, are for all practical purposes functionally illi-terate. Therefore, It is difficult to communicate with these community members via written communication. The only effective way to get data to them is verbally and even then an active/reflective listening style needs to be adopted to make sure both parties have the same understanding.

    Native American Family Advisors/Advocates would receive comprehensive training on working on behalf of service providers. They would also meet regularly with the three Native American Indian Sub-state Coordinators to identify client problems needing resolution and undertake ombudsman-like intervention with various State Agencies and health care providers.

    Also under the Statewide Program Director’s leadership would be a Fiscal, Data Quality and Research Unit to provide grant writing and contract support. It could employ a Fiscal Director; Data Collection and Quality Assurance staff and Research and Grant/Report Writing staff. However, it may be possible that State agency staff or contractors could be assigned for short term periods to assist the non-profit in grant application development and writing. This unit would develop close working relationships to Native American entities that receive and manage various grants and contracts.

    Federally recognized Tribes, because of a deep respect for their sovereign nation-to-nation concerns, may not formally choose to become a partner in such a non-profit corporation. However, they might be willing for their tribal members to participate independently as board members or on a board of advisors to the non-profit corporation.

    If the State of MA makes a sincere and demonstrated commitment to formalized Native American interchange, as has been the case in Wisconsin, the MOUs will then become a valuable means to strengthen communication and resolve health care disparities for this vulnerable population.

    This is not to say that some state agencies are not very committed to work with Native peoples (i.e., the Mass Commission on Indian Affairs and the Department of Public Health). How-ever, most agencies lack the resources to do more than what they already do. This means that a serious commitment must be made at the executive level. What has been missing is authority that can commit and sustain needed resources from the executive and legislative branches of government.

    The American Native leadership’s need is for a planning grant that would allow active facilitation of Native Americans becoming recognized by the State and non-federal funding organizations and provision of assistance to mainstream service providers to enhance awareness of Native American cultural sensitivity and to improve Native American access to needed services and follow up assistance.

    • ONC Blog Team says:

      We look forward to working with the Native American community, and all groups with clearly defined disparate health outcomes to make this plan as effective as possible. Thank you.

  7. With respect to Goal 4, Point 2. Accelerate individual and caregiver access to their electronic health information in a format they can use and reuse

    I worked in a healthcare system where 40% of patients were language minority patients. The system was trying desperately to have them engage in their electronic health information, but the program only came in English. It is imperative that these programs be CLAS compliant by allowing for multilingual formats of else language minority patients will be left behind and healthcare organizations will not be able to achieve their engagement goals.

  8. Tee says:

    interested in how mobile applications can assist in increased awareness for Health care in underserved/minority communities. Keep us posted

  9. Eileen Rivera Ley says:

    I am very concerned about the accessibility of future health IT. For decades I have worked to advocate for blind and low vision persons, and have done work around diabetes and blindness. So much health technology is not fully accessible, or even usable because developers overlook the need for nonvisual and low vision access to digital displays, electronic information, and consumer interfaces. I urge you to include some objective regarding access. Blind health care workers, and blind health care consumers are at risk. Already too many websites, phone aps, insulin pumps, glucose sensors, patient registration kiosks, ect are not accessible. Thank you for remembering the access needs of this underserved population.

  10. AJ Chen says:

    Goal 4 for empowering individuals is critical. In addition to EHR, new health tools for consumers to use are required to make the empowerment happen. Many tools will likely come from the emerging consumer health technologies industry. However, as the industry has found out in a hard way, the healthcare market is not exactly a free market system, where innovations have difficult time to become sustainable products and services. Thus, I would like to see a new objective under Goal 4 that outlines what the government can do in order to assist commercialization of new solutions for closing disparity gap. It could be policy changes, funding, public-private partnership, or anything that helps building a viable consumer health technology industry.

  11. Michelle Jones says:

    I am concerned that too much emphasis is being put on the use of technology to a population of people who do not make use of that as a medium for anything…when we speak of health disparity, for example a large population is the elderly and their communication network is not relying on this medium. Communication vehicles maybe color bind but do good work. Like senior centers, church groups, AARP, community action agencies, shelters for the homeless, women groups, women’s shelters and local health and social coalitions that are advocacy related.

    Some areas do not have HBCUs and I can only hope that they are indeed, providing a vehicle to the communities where they are located. I maybe simply unaware of their linkage to any community.. .some work needs to be done to educate family members who serve as the caregivers and information source to their families.

    Let’s go with movie with a message–a campaign of sorts that really calls attention to access and information….

    Consider linking with professional groups that are not medical related but have an interest to make a difference.

  12. with my wife we are always happy when science and advances in health come together to help those who need it most. Thanks for this post I made ​​my day

  13. Andrea says:

    I like that you plan to work with HIT vendors to use reduced rates for MUA providers.

    I also want to echo Lisa Eng’s comments on accessing personal health records. Alternative options should be considered for patients that do not have access to or cannot afford text messaging, mobile internet technologies, or even computers in their homes. Maybe HHS could work with providers to have separate area where patients could look at their personal records in their office?

  14. Information Technology has infinite implications for the healthcare of our country. Records management, diagnosing faster, doctor rapport….you name it. Learning more about the developments in this field are critical.

  15. Bro CES says:

    Good Morning,

    I agree with the information so far including the Goals, What I don’t see are have missed , is the delivery system in place for the far reaching part, that will reach into the most hidden coners of the public. Some mention the homeless and that is good , but there is also those who are hidden within the House that need to be reached as well. Will there be Funding for messageing ? I’m founder of an Health Ministry which is Faith based with outreach. to 30 churches and community base organizations. Even with this the process of message outreach is large and time consuming. I’m quite sure everyone will be doing what they can to get the word out. I hope the funding is fair so everyone can participate in getting the word out including all forms of media Thanks.

  16. I commend ONC and HHS OMH for undertaking to put together this document. Almost two years ago I put together a document and appeared before a congressional subcommittee to discuss this very issue. What a bulleted list misses is a sense of the prioritization of the objectives as well as the need to understand the big picture issues which underly the need for such a document in the first place.

    First, underserved communities and populations are often the last to benefit from advances in science, medicine and technology. Health information technology is most important for those who need help understanding health information, explaining their conditions to health are providers, and coordinating their own health care. So our neediest patients must get access to the benefits of HIT early and thoroughly in order that this technology does not increase health disparities. To accomplish this, community members must be heard and must be participants in the development of our plans. With all due respect for the openness of this computer forum for comments, it is unlikely that many comments will be received from those living in MUAs and even more unlikely that the homeless, the disabled and folks who are otherwise disconnected from the healthcare system will be reading this call to action. Furthermore, its availability only in English will limit the comments from any non-English-speaking constituents. So we must, through meetings in the community, outreach to those in most need – define our plans to meet their health care needs. We recently ran focus groups among homeless folks we care for in our centers to discuss HIT and the only consistent medium that they have access to, if any, is cell phones. They were very interested in accessing their own health information – as long as it could be accessed by cell phone and messages were sent to them via text.

    Second, language is a major issue for many racial and ethnic minorities. EHRs are in English, and patients who would like to use a PHR (personal health record) will find it difficult to access resources in any other languages. We must realize that excluding mechanisms for non-English-speaking folks to access health information will increase disparities.

    Third, while the EHR incentive program is being used to stimulate the meaningful use of health information technology, we need to go beyond this to Federal and State mandates that kick-in where incentives will be inadequate to stimulate development and implementation. We do not want to discourage providers from adopting EHRs but at the same time, we need to make it clear that that beyond some future date, the Federal government, through Medicaid, Medicare, and their other programs – will no longer pay for services at the same rate if the service is provided in a non-electonic environment.

    In summary, the document being produced would benefit from a more through preamble and stage-setting in order to drive home the importance of the goals and objectives stated within. A mechanism needs to be developed to get input from the very people that the document is attempting to protect and support.

    Neil Calman MD
    President and CEO
    Institute for Family Health
    New York

    • ONC Blog Team says:

      We are working to refine all aspects of this plan. Our hope is to encourage and receive more feedback from the communities that will benefit most from this work. We are grateful for constructive comments such as this.

  17. Ctilley says:

    Sadly the proposal and request for feed-back embodies nearly every one of the attributes that we are trying to change in reducing disparity. It is online only.. It is written at a 12th grade reading level.. The long list of acronyms and govt agencies and grants does little to engage actual consumers or patients and instead seems to be a smorgasborg of programs and studies. The focus should be on the patients needs not on the technology itself.

    As many have mentioned the section titles and lay-out is confusing.. Apparently the terms in Bold are the Health IT strategic plan and the Gray Objectives below are the strategies and tactics to reduce disparity? One strategy should be to drive down the cost of care so that we can expand actual coverage to as many people as possible. there is little sense in worrying about literacy or rural vs urban when 20% of the population lacks any consistent access to a health care provider.

    Why not list each strategy and have a way for people to simply vote it up or down?

    • ONC Blog Team says:

      Thanks for your suggestion Carol. We are launching a brand new site this month which is geared to removing any barriers that prevent people from understanding what Health IT is, what it means for them and what is currently available. We hope that you will check back in couple of weeks and see if we have hit the mark.

  18. Glenntheteacher says:

    As highly sensitive and confidential information is becoming electronically converted and will be readily shared within the Healthcare Industry, the special needs and privacy concerns of the HIV+ / AIDS diagnosed individuals will need to be addressed. Many within this population are underserved and many are reluctant to seek care now. A special section needs to be devoted at educating this subset that their privacy and confidential information (i.e. HIV / AIDS status) won’t be compromised.

    “Goal 3.1″ touches on this – and I would hope that leaders within the HIV+ / AIDS communities are part of this education and reassurance to the general population as this is rolled out.

  19. Arika Makena says:

    I think that the specifics of how individual groups are reached needs to be a lot more thought out. You won’t reach the majority of African-Americans through Black universities alone. Extensive outreach needs to be done through churches, schools, libraries, and community-based programs. Access points for some of these technologies could be set up in local libraries, churches and institutions that people trust.

    African communities must also be addressed, and in the case of refugees many may not have had previous exposure to these sorts of technologies at all. How will their culturally specific needs be addressed?

    I think that Community Health Workers could be trained in the new Health IT technologies and used as liasons with their culturally specific communities to increase access and equity.

    As a Community Health Worker and member of several marginalized communities, I must stress that transparency is the name of the game. The more patients and underserved populations understand about how these technologies are to be used and how they work, the more we will be able to engage with them.

  20. Nate Osit says:

    This is a good start! Some points-

    1) I think that while there is Health IT outreach to MUAs going on, it would be helpful to provide free, open source software as an option for providers. This could include open source EHRs, but also office tools, scheduling software, image editing, and the rest of the wide array of free, open source software currently available. Especially considering the effort that has gone into VistA, it would make sense to make these and other resources available.

    2) It might be useful to have a repository of translated medical terminology that could be easily integrated into EHR software. There are so many languages used in the US, I imagine that it would be quite burdensome for each vendor to create their own translations, especially if they wanted to confirm their accuracy. If there were a centralized repository which was reviewed by native speakers, I think this would make the task of translating to all languages more achievable.

    3) Putting this out for comment isn’t enough. I’m not sure what sort of outreach is being done, but I would hope that the ONC is speaking directly to Community Health Centers, Homeless Shelters, HIV+/AIDS organizations, and others who are the most greatly impacted by health disparities.

    4) It may be useful to have a way to get paper copies of digital records. For those without regular computer access, printing out sensitive information at a public library may be too stressful. If there were a way to have the data printed and sent to patients, I think this could alleviate this unnecessary stress. Another possibility would be to ensure that providers know how to print a full copy of a patient’s record, so that it can be shared during a visit.

    5) It might be helpful to work with other agencies like the FCC to do outreach to address digital disparities while working on health disparities. One possible collaboration could be grants for technology tutorial outreach to senior centers. I’m sure there could be many more collaborative efforts, and many who would like to contribute.

    I think this is an important initiative, and I hope it is very successful!

  21. I would lke to echo the comments made bylisa Eng, Isabel ARocha, Michelle Jones and Eileen Rivera Ley. As much as I am glad that the health IT movement is considering how to address health care disparities, I think that in practical application for the patient, we need to really understand the patient. Many patients do not have access to the mediums being considered, and if they do their access may be limited due to a language barrier, visual need, or literacy. I would like to see more supports for reaching patients who are not direct beneficiaries of health IT advancements.
    I also would emphasize the need to focus on supports to allow for the meaningful collection of patient-level data so that measures of health disparity are more accurate and more useful at both macro and micro levels.

  22. Chris Gibbons says:

    I think it is commendable that ONC is working to address the issues of Healthcare disparities. I find much to like in this strategy and offer the following comments as suggestions to further enhance your work.

    While there may not be consensus as to the causes of health, Healthcare or Health IT disparities, it is increasingly clear that disparities are a complex phenomenon resulting from the interactions of many factors. Also, with almost a decade’s worth of the National Healthcare Disparities Reports behind us, it is clear that addressing disparities defies simplistic solutions. As we all believe that the complexity of cancer, cardiovascular diseases and HIV/AIDS will not stop us from one day finding a cure, I firmly believe that this same tenacity of spirit is needed to successfully surmount the challenges of disparities. Rather than seeking a “magic pill” or single set of policies/practices/programs that can “solve” the problem for all, we need people, policies and programs that educate, encourage and support every provider, healthcare professional, hospital , patient and caregiver to consider their role in the generation or elimination of disparities. When this tipping point is reached, momentum will inevitably propel the policy, practice, regulatory and IT innovation that will be needed to successfully achieve the vision of an equitable healthcare system and health outcomes.

    So, my first comment is, as you can see above, more philosophical than programmatic or policy oriented. Yet I think it is very practical. Strive to develop a strategy that at its core galvanizes the populace to become involved in this issue, to see it as “our” issue rather than “their” issue and to recognize that “inequities among some inevitably threaten equity for all”.
    Secondly and even more specifically, it is not clear what disparities or target audience is being envisioned as the focal point of this strategy. Goals must have a clear target. Without this they are unlikely to be successfully achieved.

    Thirdly, the metrics that will be used to evaluate achievement of these goals are not specified. Without a plan to measure progress or clear methods of doing so, it will not be possible to convincingly document success.

    Fourth, the overwhelming focus of this strategy appears focused on medical providers and the healthcare system. While there is some inclusion of patient engagement and consumer health informatics there seems to be little appreciation that all patients will not be able to, of themselves, become engaged. Thus the role of formal and informal caregivers and Health IT must be integrated in to any systems oriented strategy. Incidentally, research has shown that reliance on formal and informal caregivers and care giving burden is higher among many disparity populations. The extent to which we are able to improve outcomes in general and improve disparities in particular will in part be related to the ability of formal and informal caregivers to provide needed “care” and to receive the supports they will need to adequately do so. Similarly this strategy does not seem to speak to the potential role of Health IT in enhancing chronic disease self management. In that the major causes of morbidity and mortality today are chronic diseases, patients and caregivers alike are struggling with these illnesses for protracted periods of time, yet are in the personal or technology-mediated presence of a medical provider, for relatively short periods of time, over the lifespan. If all we do is use Health IT to improve what occurs in the traditional clinical encounter, without addressing patient/caregiver interaction between encounters through Health IT, we are unlikely to sustain patient engagement efforts, improve provider-patient communication or reduce disparities, particularly over the long term.

    Finally, this strategy does not appear to speak to the fact that providers and patients alike live in dynamic and changing environments with changing needs and issues. Even a perfect plan will not remain perfect forever. A sound strategy must be iterative in nature and intentionally evolve over time, as our nation evolves. Managing expectations along these lines will be critical to the long term success of the strategy and should start from the very beginning.

    I hope you find these comments and suggestions helpful.
    I wish you much success!

    M. Chris Gibbons, MD, MPH
    Associate Director, Johns Hopkins Urban Health Institute
    Baltimore, MD

  23. Jared says:

    Is this a real request for public comment? By that I mean, has this request been published formally in the Federal Register, and is there an office that has been tasked with formally reviewing and responding to the comments, as occurs with other requests for public comment?

    I have never before seen a request been made in which the official instruction was to post a text comment at the end of a blog entry. Yet I cannot find anything to the contrary in any recent issues of the Federal Register. Please advise. Thank you.

  24. I do agree with Amy and others concerning CLAS compliance and IT informing our Patient Centered strategies. Another EMR capability needs to be public health reporting. The ability to have reports that looks at Quality Indicators stratified by Race, Ethnicity and Language preference and if possible country of birth would be a great way to inform strategic outreach plans for the local communities they serve. Lets face it, resources are scarse, lets invest in the areas that will have the largest impact.

    Marcos Pesquera
    Center on Health Disparities at Adventist HealthCare
    Rockville, Md.

  25. David Heckman says:

    I did not see who would pay for the treatment. I know treatment for illness can cost millions, I do not know at this time can the tax payers pay for the treatments. I know many times the individual can’t and that should be considered.

  26. This biggest thing missing in the plan is that it doesn’t address the rural health disparities which are becoming wider because the HITECH Act incentives are not available for Rural Health Centers. The legislative oversight that wrote them out of the incentive program prevents them for taking advantage of the same incentives available to every other provider in the country.

  27. Ellen Wu says:

    We support the proposed plan, with the following comments:

    Goal 1, Objective A
    • In addition to prioritizing providers in Medically Underserved Areas, Medicaid providers eligible for HITECH incentive payments (who have at least 30% Medicaid patients, or 30% “needy patients” for community health centers) should also continue to be prioritized as safety net providers in future HHS grant programs supporting HIT

    • Support more open source software, electronic health record systems, and personal health records such as the Direct Project to make such HIT affordable or free to providers within underserved communities and the underserved patients

    • In addition to the plan’s inclusion of Hispanic Serving Institutions, Tribal Colleges and Universities, and Historically Black Colleges and Universities, add the Asian American Native American Pacific Islander-Serving Institutions to the list of minority serving institutions that could support HIT workforce training programs http://www2.ed.gov/programs/aanapi/index.html

    Goal 1, Objective C
    • In addition to race and ethnicity as mentioned in the plan, add stratification by primary language

    • Encourage ONCHIT and CMS to adopt the recommendations of the Institute of Medicine for collection of granular ethnicities and language assistance needs as Stage 2 meaningful use requirements http://www.iom.edu/Reports/2009/RaceEthnicityData.aspx

    • Encourage ONCHIT and CMS to adopt the recommendations of the Institute of Medicine to collect data on sexual orientation and gender identity in EHRs http://www.iom.edu/Reports/2011/The-Health-of-Lesbian-Gay-Bisexual-and-Transgender-People.aspx

    • Consistent with ACA section 4302, collect data on disability status in the EHR

    • Collect data on health literacy (e.g. highest educational level achieved) in the EHR

    Goal 2, Objective B
    • Consider adoption of the National Quality Forum Comprehensive Framework and Preferred Practices for Cultural Competency as a source of measures for disparities reduction

    • Consider adoption of the National Committee for Quality Assurance Distinction in Multicultural Health standards as measures for disparities reduction

    • Consider adoption of health-related quality of life measures to encompass those aspects of overall quality of life that can be clearly shown to affect health—either physical or mental

    • Collect data on community conditions, aggregation should happen broadly across multiple dimensions (ethnicity, sexual orientation, economic status, race, and geography) and analyze the data in tandem with population health data collected primarily by public health departments.

    • Track referrals to community services

    Goal 2, Objective C
    • In addition to prioritizing providers in Medically Underserved Areas, Medicaid providers eligible for HITECH incentive payments (who have at least 30% Medicaid patients, or 30% “needy patients” for community health centers) should also continue to be prioritized as safety net providers in future HHS and other federal HIT and payment reform pilots, demonstrations, and initiatives

    Goal 3, Objectives A, B, & C
    • Ensure that online applications only require information that is necessary to advance an application (For example, a required field for a Social Security Number would prevent legal immigrants without a SSN from submitting an online application)

    • Develop online applications that prevent inappropriate rejection or barriers to application and eligibility, especially based on guardian’s immigration status. (For example, a child who is a citizen might need his/her parent, who is not, to fill out an application)

    • Include privacy and security protections to prevent misuses of health data peculiar to those in underserved communities, including misuses of health data to deny or restrict health care or insurance coverage, to engage in unsolicited marketing to patients and consumers, or to deny or restrict a patient’s rights under the law, including immigration laws

    Goal 4, Objective A
    • Rather than adapting the CLAS standards, the ONCHIT and CMS should consider adopting the CLAS standards as a meaningful use requirement and as a requirement for any future HHS and other federal HIT and payment reform pilots, demonstrations, and initiatives

    • Work with mobile phone carriers to make health-related text messages free (as they have agreed to with Text4Baby)

    • Work with the HHS CIO to incentivize HIT applications focused on underserved and disparities populations (in languages other than English, for lower health literacy, for disabled)

    • Maximize multiple simultaneous options/channels for communication with patients, families, and caregivers (mail, phone, email, text, etc.), customized to each patient’s preferences and consent

    • Work with other federal departments and state and local partners to increase community access points to the internet, printers, etc. where underserved patients can access their health information (public libraries, schools, senior centers, etc.)

    Sincerely,
    Ellen Wu
    Executive Director
    California Pan-Ethnic Health Network
    http://www.cpehn.org

    Kathy Lim Ko
    President and CEO
    Asian & Pacific Islander American Health Forum
    http://www.apiahf.org

    Mark Savage
    Senior Attorney
    Consumers Union of the United States, Inc.
    West Coast Office
    http://www.consumer.org

  28. Neil Abernethy, Ph.D. says:

    Some possible areas for improvement:

    1) Include more specific objectives to coordinate activities to reduce disparities across HHS divisions. These activities are too often siloed. I concur with the earlier comment encouraging tighter integration with public health authorities through public health reporting. Public health provisions should become mandatory in future phases of Meaningful Use.

    2) I would second Ms. Wu’s recommendation to “Collect data on community conditions, aggregation should happen broadly across multiple dimensions (ethnicity, sexual orientation, economic status, race, and geography) and analyze the data in tandem with population health data collected primarily by public health departments.”

    3) Consistent with (2) above, ONC should interface with the Department of Veterans Affairs and insurers to include objectives to promote and study the role of health IT to support continuity of care for the underinsured, veterans, and mobile/migratory populations.

    4) Include goals to research and promote data standards that do not reinforce disparities (e.g. allowing for intersex, transgender, multiracial individuals in medical coding, or support variable alert rules/values depending on variable clinical norms in decision support systems). These goals should be coordinated with and reflected in Meaningful Use and EHR certification.

    5) Include internal ONC policies to promote and adhere to grant/subcontract guidance on reducing health disparities. For example, the HITECH act included specific provisions to target disparities or underserved populations, but it is unclear how consistently these priorities were followed. REC local policies approved by ONC should be available for public scrutiny.

    6) ONC and HHS have an opportunity to be proactive in addressing how the availability of genomic data may impact (reduce or reinforce) health disparities, before this data is routinely integrated in EHRs.

  29. The National HIT Collaborative for the Underserved (NHIT) commends the efforts by the Health IT Disparities Workgroup, led by the Office of Minority Health and ONC, to develop the Federal HIT Disparities Strategic Plan. We appreciate the opportunity to provide input on the plan. Before offering specific comments on the strategies or tactics, we offer the following high level comments.

    The goals and objectives included in the Federal Health IT Strategic Plan, updated and published by ONC this month, highlight the role of health IT as a critical enabler in the transformation of the healthcare system. NHIT supports the adoption of these goals and objectives in the Federal HIT Disparities Strategic Plan. It should be noted that the Institute of Medicine found in Crossing the Quality Chasm that eliminating health disparities is a prerequisite for achieving health care quality.

    Healthy People 2020 defines a health disparity as “a particular type of health difference that is closely linked with social, economic, and/or environmental disadvantage. Health disparities adversely affect groups of people who have systematically experienced greater obstacles to health based on their racial or ethnic group; religion; socioeconomic status; gender; age; mental health; cognitive, sensory, or physical disability; sexual orientation or gender identity; geographic location; or other characteristics historically linked to discrimination or exclusion.”

    We also recommend that you consider incorporating elements of the evolving National Quality Strategy and the National Prevention Strategy within the strategies articulated in the Federal HIT Disparities Strategic Plan. The National Quality Strategy and the National Prevention Strategy both emphasize the importance of using community-based resources to promote preventive health. Community health and non-clinical organizations, with assistance to provide affordable healthcare services, and/or to conduct culturally/linguistically appropriate education and outreach efforts, can accelerate the access to preventive healthcare needed to address health disparities. These community resources also can play an important role in advancing the goals of empowering individuals and inspiring trust in health IT.

    Goal I: Achieve Adoption and Information Exchange through Meaningful Use of Health IT

    Strategies Supporting Objective A

    1. Grant programs that focus on EHR incentive payments to providers must link increased measurement and reporting to government to improvements in quality care and health outcomes for diverse populations served. In addition, incentives should also be linked to improved care coordination where there is evidence or documentation of engagement of the patient and all members of their care team (clinical, educational, and interventional).

    2. The measures used to determine the “practical” and “effective” methods to achieve adoption and meaningful use of health IT by providers within underserved communities should be flexible and evolve as the evidence base of best practices applicable to these communities grows.

    3. Providers will need a range of assistance and support to effectively select and implement certified EHR technology. This will be the case from the early stages of adoption through post implementation. Assuring effective adoption of EHRs goes beyond tracking providers in underserved areas; it begins with a requirement to hold RECs accountable to support a targeted percentage of providers in racial/ethnic and other underserved communities. NHIT recommends that the Federal HIT Disparities Strategic Plan require CMS to gather and report on the number of non-hospital based providers for whom a threshold number of their patient population is a member of a racial or ethnic minority or who are serving a specified percentage of people in a medically underserved community or health professional shortage area.

    4. Support for health care providers will be necessary for implementation and continuous upgrades to certified EHRs beyond the current 2014 funding of the RECs. Stage 3 of MU is anticipated to occur in 2015 and Medicaid incentives for MU extend to 2021. The expanding set of quality measure requirements for payment across all programs, including information exchange requirements, signal an escalating demand for automated data and information capture, exchange and reporting. NHIT recommends that the Federal HIT Disparities Strategic Plan include a requirement that CMS, ONC and OMH monitor and report on the number of providers attaining MU in stage 1 but who do not progress to the later stages where the improvements in care, efficiency and population health are expected to occur.

    Strategies Supporting Objective B

    1. NHIT recommends that the federal government continue to work with state governments in the continuing development of state health information exchange, leveraging federal programs to support business models for exchange, and prioritizing the inclusion of federal health safety net programs and providers in the exchange, particularly those who serve in underserved communities, with a focus on communities of color.

    Strategies Supporting Objective C

    1. NHIT urges the inclusion of metrics in reporting requirements in federal cooperative /contractual agreements that capture the percentage of information exchange between public health agencies and providers in underserved communities. These results should be made available to the public. Applications for participation in public payment programs, demonstration or permanent, should require that applicants capture and report the number of primary care providers (PCPs) in medically underserved communities and communities of color who are participating in the respective program.

    2. NHIT recommends that the Federal HIT Disparities Strategic Plan require HHS agencies to plan for the inclusion of long-term care and dental care providers in this strategic plan. Their omission would be a missed opportunity to bridge significant gaps in services to underserved communities.

    Goal II: Achieve Adoption and Information Exchange through Meaningful Use of Health IT

    Strategies Supporting Objective A

    1. NHIT urges the inclusion of a provision in the Federal HIT Disparities Strategic Plan that anticipates the need for, and plans for, the development of a voluntary process to certify health IT devices and applications for cultural, linguistic/literacy, and human factors’ appropriateness for use among one or more vulnerable populations.

    Goal III: Inspire Confidence and Trust in Health IT

    Strategies Supporting Objective B

    1. Final regulations implementing the modifications to the HIPAA Privacy and Security Rules and Breach Notification must be communicated to the public through multiple communication methods, to support public awareness of the new rights, and government tools to protect their rights. Provide for the dissemination of this information in culturally and linguistically appropriate formats through trusted channels with the demonstrated capacity to reach specific racial/ethnic and other underserved communities.

    2. NHIT recommends proactive communication to the public concerning findings and results produced by ONC and CMS grantees and contractors with respect to pilots and demonstrations where new approaches to the sharing and protection of personal health information were deployed.

    Goal IV: Empower Individuals with Health IT to Improve Their Health and the Health Care System

    Strategies Supporting Objective A

    1. NHIT concurs with the strategy to determine if CLAS Act and its National Standards must be adapted to encompass health messages delivered via mobile devices. We also recommend determination of appropriate literacy levels for information communicated to individuals and use innovative strategies to compensate for low literacy levels in the consumer’s preferred language. OMH should play a leadership role in such efforts, in collaboration with ONC, AHRQ and other federal agencies.

    2. NHIT also strongly recommends that HHS invest in outreach and education efforts which are focused on consumers in communities of color and other underserved communities and that engage national and community-based organizations that are trusted by those communities

    Goal V: Achieve Rapid Learning and Technological Advancement

    Strategies Supporting Objective A

    1. NHIT agrees with the strategy to link comparative effectiveness research, where applicable to health IT grants and programmatic outcomes, and urges a comparable linkage to research from the Patient-Centered Outcomes Research Institute, and the Agency for Healthcare Quality and Research. NHIT recommends that these agencies work closely and collaboratively with OMH on these research projects.

  30. The Association of Clinicians for the Underserved says:

    ACU Public Comments on Federal Strategic Plan to Reduce HIT Disparities

    The Association of Clinicians for the Underserved (ACU) appreciates the opportunity to comment on the efforts of the Health IT Disparities Workgroup, led by the Office of Minority Health (OMH) and the Office of the National Coordinator for Health Information Technology (ONC). ACU is a nonprofit, trans-disciplinary organization of clinicians, advocates and health care organizations united in a common mission to improve the health of America’s underserved populations and to enhance the development and support of the health care clinicians serving these populations.

    The recently released Federal Strategic Plan to Reduce HIT Disparities proposes goals and objectives to improve the overall safety, efficiency, and quality of care. The Plan is specifically intended to address disparities in HIT among vulnerable populations. We commend OMH and ONC for developing and releasing this proposed plan and we agree that the collection of data is foundational to efforts aimed at eliminating health disparities.

    Although this plan is a good step forward, we believe that it can be strengthened and have developed the following general comments:

    1) There should be a focus on a transdisciplinary approach between various health care team players such as physicians, physician assistants, social workers, nurses, and community health workers to help reduce disparities in HIT. It is great to work between and within federal agencies, but these other individuals can help provide compelling insight on improving the quality of care since they work directly with minorities and other vulnerable populations. Transdisciplinary care is important to ACU as we believe that it improves health outcomes by limiting gaps in health care and patient education. ACU also encourages the HIT workforce to engage with clinical teams to understand the language culture and literacy challenges of moving this special population to trust and engage in tools of HIT.

    2) There should be a greater emphasis placed on identifying the various successful HIT pilot systems, like the Beacon Community Program does, and then emulating and adopting those models instead of developing new ones. Starting from scratch may take more time, effort, and money to implement.

    As a member of the National HIT Collaborative for the Underserved (NHIT Collaborative), ACU supports its public comments on the Federal Strategic Plan entitled, “Comments on Federal HIT Disparities Strategic Plan for NHIT Collaborative,” as well.

    Again, these goals and objectives are a step in the right direction by providing necessary information to effectively reduce health disparities. Through this public comment period, we encourage that this plan is carefully evaluated as to whether it is as effective as it can be.

    ACU reiterates its commitment to work with OMH and ONC as it implements the Federal Strategic Plan to ensure that minorities and other vulnerable populations have access to HIT and better health care. We believe that the ACU has the capability to assist these agencies with identifying successful HIT systems that focus on the underserved because of our track record with helping the underserved and an emerging focus on HIT. Together we believe that we can move our nation one step closer to achieving health equity and reducing health disparities.

  31. Ty Faulkner says:

    ***Ty Faulkner is Lead Coordinator for the non-profit community-based organization called Urban Healthcare IT Privacy Protection (UHIPP). He is also Vice President of Business Development at Weno Healthcare Inc., a growing eCommunity and eHealth Exchange. Below are Ty’s comments on…GOAL #3 – INSPIRE TRUST in HIT

    I believe to truly prevent a further “digital divide” on confidentiality, integrity, and availability of health information technology in urban & underserved populations of color, we need specialized strategies for provider and consumer education in urban and underserved communities of color. Therefore, my comments below will focus on the needs of the urban underserved communities of color as it relates to security, privacy, & trust of health information technology:

    COMMENTS:
    -How about starting with a quantitative benchmark questionnaire on “Trust Verification of HIT” using the top 10 underserved communities in USA. This questionnaire can be done via online, on-site, and mailed surveys with at least 500 -1000 provider responders from the urban communities of the underserved people of color and used as representative national data (a similar consumer questionnaire should be considered as well). The questions we need to know about are basic on what’s going on in the community in regards to trusting HIT, trusting meaningful use 1-3 to ultimately reflect/address the needs of underserved communities, security privacy processes that are underway or lack thereof, confidence in their EHR systems security/breach protection, and the local providers ability to complete the required HIPPA privacy and security MU activities in stages 1-3.
    -Consider setting-up immediate online training for offices and facilities on how to create office policies for security and HIPPA privacy for PHI. This online training is already being done through the vendors. However, using a more formalized vendor donation program would help track and evaluate the training from privacy/security vendors.
    -Provide or set-up a long range advisory team of providers, policy makers, and underserved community HIT organizations to make recommendations of “REAL WORLD” examples of underserved community populations and providers on security privacy capabilities & needs. For example, underserved areas may need specialized training & examples of electronic data destruction policies.
    -Add more financial incentives and additional time for security privacy MU adoption in underserved areas due to slower HIT adoption (%) stage 1 during 2011.
    -Use local “boots on the Street” approach including Radio, TV, Text4Health, gasstation TV, churches, in-theater ads and more to provide information to individuals of their rights regarding the uses of PHI. Just using typical means of information dissemination (office handouts to patients) to educate in the underserved communities on HIT privacy and security may not get the job done.
    -My group UHIPP, and many other groups like mine that serve in the underserved community are fully engaged and ready to support security privacy & HIT trust awareness initiatives. It seems unreasonable though to ask groups to continue to recruit providers in underserved areas for HIT adoption without providing the financial resources to so. We eagerly have tried to coordinate with existing channels, yet have been turned away while even more help is still need from the community based groups to create and disseminate resources like multi-lingual HIT information, computer security/privacy training, HIPPA, data breach preventation and breach follow-up policies in the underserved areas. So, consider setting up more direct means to support community based groups like UHIPP.
    -As an instructor in the Community College Consortium program in Michigan, I’d (Ty) would like to see us create more entry level opportunities for the well trained HIT GRANT WORKFORCE 2.0 students from institutions like mine at Macomb Community College in Warren, MI and other RCCs. These students are well trained and want to work even as volunteers or interns. Why can’t we set up a process geared towards creating entry level volunteer positions or (vendor donation) supplemental internships using RCC students to review & prepare offices for data security audits, helping with data usage protection methods, selecting trustworthy technology, or helping underserved community based providers in building office security policies and practices.

    Thank you,
    Ty Faulkner
    Lead Coordinator
    Urban Healthcare IT Privacy Protection (UHIPP)
    ty@wenohealthcare.com

  32. Goal I: Achieve Adoption and Information Exchange through Meaningful Use of Health IT
    Objectives
    A. Accelerate adoption of EHRs
    B. Facilitate information exchange to support meaningful use of EHRs
    C. Support health IT adoption and information exchange for public health and populations with unique needs

    Under Objective A, the proposal to “partner with the National Medical Association, National Hispanic Medical Association, National Council of Asian & Pacific Islander Physicians, and other minority health care provider advocacy organizations to facilitate meaningful use…” requires ongoing dialogue. Minority physicians are more likely to need the assistance of ONC and OMH, and are more likely to see patients from vulnerable populations. All the tools available through ARRA and ACA – such as Regional Extension Centers (RECs) – should be advertized over and over again to this target audience. The reach and impact of the RECs have been called into question across the country, since many of them had to build relationships from scratch, especially in minority communities. Consequently, the rate of HIT adoption among minority providers in many states has not kept pace with expectations. Some RECs have been more successful. Their approaches should be emulated to the degree possible.

    Recognizing vendors who work “extensively” with underserved communities – some vendors have been reluctant to interact with minority providers, but our members would be more favorably disposed toward vendors who offer more financing solutions than the competition. Vendors should be duly advised.

    Objective C is critical to achieving Objective B. Without properly collected data, it will be impossible to measure our progress toward achieving health equity. Having said that, asking providers to track an endless amount of quality measures will likely result in providers spending more time trying to make the numbers look good, rather than getting the patient back to health. Collecting data should always be in the service of informing quality and improving outcomes.

    Goal 2: Improve Care, Improve Population Health, and Reduce Health Care Costs through the Use of Health IT
    A. Support more sophisticated uses of EHRs and other health IT to improve health system performance
    B. Better manage care, efficiency, and population health through EHR-generated reporting measures
    C. Demonstrate health IT-enabled reform of payment structures, clinical practices, and population health management
    D. Support new approaches to the use of health IT in research, public and population health, and national health security

    These objectives require close collaboration between physicians and the public health community. ONC and OMH can help facilitate this dialogue, especially within the context of HIE.

    Goal 3: Inspire Confidence and Trust in Health IT
    A. Protect confidentiality, integrity, and availability of health information
    B. Inform individuals of their rights and increase transparency regarding the uses of protected health information
    C. Improve safety and effectiveness of health IT

    The financial services and telecoms industries have found a way to improve the integrity and security of their customers’ sensitive personal information. The technologies that protect us from security theft are also improving. Health care can learn from all of these industries.

    Goal 4: Empower Individuals with Health IT to Improve Their Health and the Health Care System
    A. Engage individuals with health IT
    B. Accelerate individual and caregiver access to their electronic health information in a format they can use and reuse
    C. Integrate patient-generated health information and consumer health IT with clinical applications to support patient-centered care

    Mobile technologies are vital for achieving these objectives, given that the most vulnerable populations are increasingly more comfortable with mobile phones and social media.

    Goal V: Achieve Rapid Learning and Technological Advancement
    A. Lead the creation of a learning health system to support quality, research, and public and population health
    B. Broaden the capacity of health IT through innovation and research

    It is probably most useful to consider incorporating what we learn here into medical and health professions curricula. Such a conversation should be initiated between ONC, OMC, and perhaps AAMC, and any other relevant stakeholders.

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