What Public Policy Is and How to Help Shape It David Bates, Meryl - - PowerPoint PPT Presentation
What Public Policy Is and How to Help Shape It David Bates, Meryl Bloomrosen, Doug Peddicord AMIA Annual Symposium Monday, October 24, 2011 12:00 -1:30 pm www.amia.org Overview of Workshop and AMIAs Public Policy Committee Activities
David Bates, MD, MSC Chair, AMIA Public Policy Committee
Senior Vice President for Quality and Brigham and Women's Hospital Chief of the Division of General Internal Medicine and Primary Care at Brigham and Women's Hospital Professor of Medicine Harvard Medical School Professor of Health Policy and Management Harvard School of Public Health .
– Appreciate the complexities of federal policy making as it affects biomedical and health informatics – Respond to requests for comments about rules impacting biomedical and health informatics – Understand how individuals can impact decision-making about biomedical and health informatics policy – Utilize congressional visits to advance AMIA's policy agendas – Understand how to take action to advance policy priorities that impact biomedical and health informatics professionals
AMIA’s Policy Program and Activities- David Bates
How Policy is made Inside the Beltway- Doug Peddicord
Responding to a Request for Comments – Meryl Bloomrosen
Adjourn
– ONC Health IT Policy and Standards Committees
– Meaningful Use – Privacy and Security – Metadata – Common Rule
secondary use of health data: an American Medical Informatics Association White Paper
a report of a working conference of the American Medical Informatics Association
research; implications for national policy: a report
health policy conference.
Consequences of HIT and Policy
Informatics
Data Capture and Documentation
Doug Peddicord, PhD President Washington Health Strategies Group
S
world.com/ lessons/ civics/ lp.bill_t o_law.htm net .org/ i4a/ pages/ index.cfm? pageid=291
Care (1991)
(1996)
See www.nap.edu or www.iom.edu
Advisory Committees – Commission on Systemic Interoperability (CSI) mandated by Medicare Modernization Act, 2003; report in 2005 (www.endingthedocumentgame.gov) – American Health Information Community (AHIC) (2005-08)
advisors to Office of the National Coordinator for Health IT (ONC) – Health IT Policy Committee – Health IT Standards Committee
– Testimony on local issues – Visits with legislators – Organize an e-mail or letter-writing campaign
Submitted written comments to the following (from among an astonishing number of guidances, proposed regs, reports, etc. issued):
Meryl Bloomrosen AMIA Vice President Public Policy And Government Relations
After Congressional bills become laws, federal agencies put laws into action through regulations. This process may include the following steps:
Regulatory Agenda
timeframe
Records Administration in the U.S. government's Federal Register.
www.regulations.gov
Regulatory Agenda (also known as the Unified Agenda or Semi- Annual Agenda).
each agency plans to issue or has recently completed.
proceedings that are planned, underway or recently completed. Individual entries contain a variety of information about each rule, including: – Brief description (abstract) of the rule – Timetable showing any past or projected actions in connection with developing the rule – Contact person for further information – Potential effects of the rule and related matters
they regulate their respective programs.
industries and economy. These rules are not created arbitrarily or in a vacuum. They are formed with the public's help.
commenting in writing on rules proposed.
consider these comments when they draw up a final rule.
places an announcement in the Federal Register on the day the public comment period begins.
libraries and colleges, and on the government websites.
can also be found on agency's Website. Instructions for finding Federal Register documents and submitting comments are found on the Federal Dockets Management System Instruction Sheet.
any special style. If the comment is written legibly or typed on standard 8- 1/2 inch by 11 inch paper, however, agencies can process the comment more effectively.
describes the planned regulation and provides background on the
the name of the person to contact for more information.
agency will accept public comments.
days, though some comment periods have been as short as 10 days
the comment period.
EHR certification standards formally published.
– agree that the reporting period for year 2 and thereafter should be the full year – support the decision that hospitals deemed as meaningful users by Medicare would not have to meet any state-specific additional requirements in order to qualify for the Medicaid incentive payment – Meaningful Use should be a national, not state-by-state, objective – support the HIT Policy Committee recommendation that CMS allow some flexibility in the “all-
important mandatory functional use requirements – believe that CPOE should, ultimately, include electronic transmittal of the order, and agree with the rule’s decision to defer this requirement during Stage 1. – suggest that recording of advanced directives be included as an MU criterion for hospitals
– believe that MU criteria specific to research should be included during Stage 2 and Stage 3 – concerned that the capture of relevant data elements, e.g., numerators and denominators, is likely to be a significant burden for participating EPs and hospitals – agree and appreciate that there should not be a higher standard in 2015 for an early adopter in comparison to requirements imposed on late adopters
At a minimum, clinicians and hospitals will need the following technologies, services, or capabilities
and maintenance
applicable)
and why. Agency regulatory decisions are based largely on law and science, and agency reviewers look for reasoning, logic, and good science in comments they evaluate.
(Electronic attachments will not be forwarded if the "Comment" box is left empty.)
foreign language, it must be accompanied by an English translation verified to be accurate. Translations should be accompanied by a copy of the
person by the last day of the comment period.
‘technical’ process.
either poetic or emotional. Regulations are usually about ‘facts and data’ and so too should comments.
examples, of course, but its tack will be aimed more at influencing ‘good’ HIT policy than at ‘correcting’ regulatory errors that would have specific impact on particular stakeholders.
requested comments.
individual, or you as an employee of a particular organization (relating to Medicare fee schedules for instance), from comments that might better reflect AMIA’s position as a thought-leader on HIT and the uses of health information.
23 meaningful use criteria are too ambitious’, but rather ‘this specific measure may be gatherable in the hospital setting, but would be problematic in the outpatient setting for the following reason (s)…’.
experiences are particularly effective, and often moving. Share them!
supported by facts. Don't copy and paste paragraphs of pre-written text from form letters or blogs or others’ documents. Don't misrepresent your position - decisions should be based on sound data and accurate facts.
illustrate your support or opposition for the “regulation” or “particular provision”.
them.
news reports of what the regulations say.
tables in the draft regulations that briefly lay out the proposed criteria and standards – it may be particularly useful to provide input based on those.
To a Senator: The Honorable (full name) __(Rm.#) __(name of) Senate Office Building United States Senate Washington, DC 20510 Dear Senator: To a Representative: The Honorable (full name) __(Rm.#) __(name of) House Office Building United States House of Representatives Washington, DC 20515 Dear Representative:
Note: When writing to the Chair of a Committee or the S peaker of the House, it is proper to address them as: Dear Mr. Chairman or Madam Chairwoman or Dear Madam S peaker or Mr. S peaker
http://www.senate.gov/general/contact_information/senators_cfm.cfm
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=%2Findex.tpl
www.senate.gov/pagelayout/legislative/d_three_sections_with_teasers/cale ndars.htm
Means for Us All” by the Staff of the Washington Post
United States Senate” by Eric Redman
Medicaid and the Uninsured, Kaiser Family Foundation. Available at: http://www.kff.org/healthreform/upload/8060.pdf
Medicaid and the Uninsured, Kaiser Family Foundation. Available at: http://www.kff.org/healthreform/upload/8061.pdf
Meryl Bloomrosen Vice President for Public Policy and Government Relations AMIA 4720 Montgomery Avenue, Suite 500 Bethesda, MD 20814 301.657.1291 meryl@amia.org