Academy Comments to HHS re 21st Century Cures Act Electronic Health Record Reporting Program

RE: Request for Information Regarding the 21st Century Cures Act Electronic Health Record Reporting Program (HHS-ONC-2018-0022-0001)

The Academy of Nutrition and Dietetics (the "Academy") is pleased to provide comments "Request for Information Regarding the 21st Century Cures Act Electronic Health Record Reporting Program" published in the August 24, 2018 issue of the Federal Register. Representing more than 104,000 registered dietitian nutritionists (RDNs), nutrition and dietetic technicians, registered (NDTRs), and advanced-degree nutritionists, the Academy is the largest association of food and nutrition professionals in the United States and is committed to a vision of the world where all people thrive through the transformative power of food and nutrition.

A. The Academy and Nutrition and Dietetics Informatics Commitment

RDNs provide medical nutrition therapy and other nutrition care services across the continuum of car--in dialysis and long term care facilities, clinics, hospitals, university settings, and private practice. Successful dietetics practice in today's rapidly changing environment requires skills in finding, evaluating, and sharing accurate food and nutrition information. The term "informatics" is used to describe the science of managing, storing, and communicating information, and through their direction and leadership, RDNs have had some success creating nutrition informatics as a new area of dietetics practice.

In addition, the Academy is pleased to note that nutrition placeholders now exist in mandated U. S. health IT standards necessary for Health IT Certification in ensuring inclusion of terms such "Diet and Nutrition" and "Food Allergies" in the ONC's 2017 Interoperability Standards Advisory. Current use of informatics in health care includes electronic health records, outcomes research, and knowledge acquisition.

The Academy's Nutrition Informatics Committee is a committee of eight members who represent the areas of practice with expertise in nutrition informatics and areas which are impacted by recent health information technology adoption efforts in the U.S. Among the committee's functions include responsibilities to:

  • Coordinate all of the Academy's nutrition informatics efforts in conjunction with the staff; and
  • Provide education and application of informatics concepts across all areas of practice to support efficient, accurate and appropriate nutrition care.

The Academy's growing resources for nutrition informatics include the Nutrition Care Process and Model (NCPM), Standards of Practice and Standards of Professional Performance, Scope of Dietetics Practice Framework, Dietetics Career Progression Guide, International Dietetics and Nutrition Terminology (IDNT), and the Electronic Health Record Tool Kit. Dietetics practitioners can utilize the NCPM, Scope of Dietetics Practice Framework, and Standards of Practice and Standards of Professional Performance documents to develop a personal scope of practice for nutrition informatics. While the NCPM provides dietetics practitioners in all practice areas with a framework for critical thinking and decision making, the IDNT gives those who are providing patient care in all care settings a set of terms that can be used to describe each step of the NCP. Use of a standardized terminology such as the IDNT ensures that dietetics practice is considered an integral component of electronic health records (EHRs) in all care settings.

B. Specific Comments and Recommendations

1) Include Malnutrition Electronic Clinical Quality Measures (eCQMs) in Certified Health IT

The Academy's Malnutrition Quality Improvement Initiative (MQii) promotes the use of eCQMs to advance evidence based, high quality care for hospitalized patients who are malnourished or at risk of malnutrition. We respectfully suggest that EHR criteria should include the calculation of malnutrition e-measures data. Conformance and test criteria to include basic nutrition screening, assessment, nutrition diagnosis and integrated care plans.

2) Health IT Systems Incorporating the Electronic Nutrition Care Process Will Be Better for Providers and Software Vendors

Joint work being done by HL7 and the Academy of Nutrition and Dietetics as part of the HL7 Electronic Nutrition Care Process Record System (ENCPRS) project is aimed at developing a Functional Profile for nutrition services EHR systems. This will promote interoperability of nutrition with other areas of healthcare and will also enable nutrition services providers to adopt EHR systems.

3) The Nutrition Orders Resource as part of Fast Healthcare Interoperability Resources (FHIR) should be considered part of a complete EHR system.

Nutrition is a critical component of total patient care and should be considered anytime continuity of care is a factor. EHR systems and downstream nutrition application should seamlessly communicate the correct and complete nutrition data for patients.

C. Conclusion

The Academy sincerely appreciates the opportunity to offer comments in response to a request for information by the Office of the National Coordinator for Health Information Technology regarding the 21st Century Cures Act Electronic Health Record Reporting Program. Please contact either Jeanne Blankenship at 312-899-1730 or by email at jblankenship@eatright.org or Pepin Tuma at 202-775-8277 ext. 6001 or by email at ptuma@eatright.org with any questions or requests for additional information.

Sincerely,

Jeanne Blankenship, MS, RDN
Vice President
Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics

Pepin Andrew Tuma, Esq.
Senior Director
Government & Regulatory Affairs
Academy of Nutrition and Dietetics