A PETITION AND REQUEST FOR HELP

Farzad Mostashari, MD

Deputy National Coordinator for Programs and Policy

Office of the National Coordinator for Health Information Technology

U.S. Department of Health and Human Services

200 Independence Avenue, NW, Suite 729-H

Washington, DC 20201 

November 20, 2012 

Dear Dr. Mostashari,

While electronic healthcare records (EHR's) are at the center of today’s healthcare transformation, we feel a more wide-scale assimilation of all the functionality available within EHR's is being delayed by a current practice among EHR companies that we wish to bring to your attention.  The cause of our concern – and that of our physician clients in the healthcare community – is that fees charged by EHR companies for implementing transcription interfaces are preventing physicians from choosing the clinical documentation modality best suited to their circumstances and preferences. This causes some physicians to delay using all of EHR's functionality.

While many physicians readily embrace their EHR’s clinical documentation tools, others prefer using dictation and transcription to generate all or part of their clinical documentation. Studies and physician feedback continue to indicate that EHR-driven workflow tools (templates, drop-downs, radio buttons, self-entered text, front-end speech recognition) for generating clinical documentation can result in a loss of productivity; an extended workday; a decline in vocational satisfaction; and, a negative change in the doctor-patient exam room dynamic.

These problems could be addressed in part for many physicians if EHR companies would eliminate transcription interface fees, thereby making this time-honored modality a more viable option. We realize the importance of structured data in moving our healthcare system to more outcome-based and evidence-based medicine, and understand the importance of capturing that data within the EHR’s structured fields. At the same time, dictation is most often used by healthcare providers for the qualitative sections of the patient encounter, where it provides important clues to a patient’s health story that are non-metric and less valuable as structured data.

Our appeal to you is to assist us in removing the financial barriers EHR companies now impose. Those barriers are repulsing and dissuading physicians from choosing dictation and transcription as their preferred modality for clinical documentation.

Our request is that you join us in urging EHR companies to abolish their current practice of charging for interface implementations, and to give physicians a broader scope of options for generating their clinical documentation.

Thank you for your consideration of our appeal.

The undersigned:

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