April 28, 2014
Karen B. DeSalvo, MD, MPH, MSc
National Coordinator for Health Information Technology
Office of the National Coordinator for Health
Information Technology (ONC)
Hubert H. Humphrey Building
200 Independence Ave, SW
Washington, DC 20201
Re: RIN 0991-AB92: Voluntary 2015 Edition Electronic Health Record (EHR) Certification Criteria; Interoperability Updates and Regulatory Improvements [45 CRF Part 170}
Dear Dr. DeSalvo:
The Academy of Nutrition and Dietetics (the “Academy”) appreciates the opportunity to submit comments on the above referenced Voluntary 2015 Edition EHR Certification Criteria proposed rule. With over 75,000 members comprised of registered dietitian nutritionists (RDNs),1 dietetic technicians, registered (DTRs), and advanced-degree nutritionists, the Academy is the largest association of food and nutrition professionals in the United States committed to improving the nation’s health through food and nutrition across the lifecycle. Some Academy members independently provide professional services such as medical nutrition therapy (MNT)2 under Medicare Part B, some state Medicaid programs, and all major private payers. While not considered as an Eligible Professional (EP) in the EHR Meaningful Use program, the Academy has been an active participant in the policy, standards and vocabulary proceedings, as evidenced by the following:
- Academy representation and comment at both the Health Information Technology (HIT) Policy and HIT Standards Committee Meetings since they began in Summer 2009
- Participation in the ONC Standards and Interoperability Framework’s Initiatives since its inception in 2011
- Contribution of resources to integrate nutrition care into ONC identified clinical terminologies and HIT standards on an accelerated timeline to promote industry adoption and use
- Have signed on at the organizational level for the ONC Blue Button Pledge
- Widespread advocacy for the use of the Nutrition Care Process3 use across the care continuum, to improve health outcomes, measure preventative capacity and assure optimal utilization of nutrition resources for patients
- Participation in Interoperability Initiatives such as Integrating the Healthcare Enterprise Connectathon, the Health Story Project and the Healthcare Information Management and Systems Society (HIMSS) Interoperability Showcase.
The Academy’s members are highly committed to improving care through direct nutrition evaluation and care using the Academy’s Nutrition Care Process across the care continuum, through education, interventions at the local, state, and national levels; as researchers and educators; as corporate dietitians supplying products or services to foodservice operations; as consultants in nutrition and wellness; and as systems analysts for EHR vendors and health care facilities.
In conclusion, we commend ONC for efforts to strengthen existing policies and lead to more effective leadership, implementation, health care system involvement, accountability, assessment, and transparency. Creating the Voluntary 2015 Certification Rule embraces the usefulness of stakeholder feedback in the EHR Adoption Incentive Program. The Academy appreciates the opportunity to comment on this important initiative and hopes to discuss these recommendations in greater detail in the near future. We are glad to serve as a resource if we can be of any help in shaping improved health care through the effective and meaningful use of EHRs. Please contact either Jeanne Blankenship at 202-775-8277 ext. 6004 or by email at firstname.lastname@example.org or Lindsey Hoggle at 202-775-8277 ext. 6014 or by email at email@example.com with any questions or requests for additional information.
Jeanne Blankenship, MS, RDN
Vice President, Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics
Lindsey Hoggle, MS, RD, PMP
Director, Nutrition Informatics
Academy of Nutrition and Dietetics
1 The Academy recently approved the optional use of the credential “registered dietitian nutritionist (RDN)” by “registered dietitians (RDs)” to more accurately convey who they are and what they do as the nation’s food and nutrition experts. The RD and RDN credentials have identical meanings and legal trademark definitions.
2 Medical nutrition therapy (MNT) is an evidence-based application of the Nutrition Care Process focused on prevention, delay or management of diseases and conditions, and involves an in-depth assessment, periodic re-assessment and intervention. [Academy of Nutrition and Dietetics’ Definition of Terms list, accessed 2 April 2014.]
3Nutrition Care Process (NCP) is a systematic process for identifying, planning for, and meeting nutritional needs to provide high quality care. It includes four interrelated steps: Nutrition Assessment, Nutrition Diagnosis, Nutrition Intervention, and Nutrition Monitoring and Evaluation. [Nutrition Care Process, accessed April 24, 2014.]