On June 26, 2009, FasterCures submitted comments on the proposed definition of "meaningful use" of electronic health records, urging the Office of the National Coordinator for Health Information Technology to ensure that meaningful use requirements for EHRs address support for clinical research at the earliest possible time. FasterCures' comments include:
- FasterCures has long advocated that one of the highest and best uses of a nationwide health information infrastructure – and one of its most underappreciated – is in accelerating the search for new and better treatments for disease. As the healthcare system addresses the challenges of widespread adoption of EHR systems, research capacity must be part of the architecture. Given the simultaneous priority the federal government has placed on comparative effectiveness research, we feel that this imperative cannot be overlooked or delayed.
- A truly effective nationwide health information network will require that a single set of standards be developed and adopted for the collection and exchange of data across all health communities, including the clinical research community. If a common set of standards for key information is not required from the beginning (in this case 2011), it will be much more difficult to require these downstream.
- One of the widely agreed-upon objectives of meaningful use is clearly to provide clinical decision support at the point of care. Clinical decision support is informed by research, and it is therefore important to include an opportunity to support clinical research through EHRs in 2011 (with standards that will be available before 2010). Similarly, if one of the stated objectives of meaningful use is “aggregating clinical summaries from multiple sources available to authorized users,” standards and controlled terminology are essential for such aggregation if it is to be useful. These should be required in 2011 so that this 2015 goal can be realized.