The Office of the ONC has begun putting together a plan to look and find areas where electronic medical records can cause harm to patients.  Two agencies, the American Medical Association and the Texas Medical Association have made comments and suggestions.  iHealthBeat has done a nice job providing a summary of the recommendations made by each.

The AMA suggestion contains a few more steps and details with administrative work required while the TMA suggestions by comparison pretty much cut down to the chase to get things moving faster.  They do have a point in the fact that within the next couple of years there will be more safety issues to arise.

I would say looking at both of them, I would choose the TMA plan as the AMA plan, while good and taking in many areas of concern it could make the process even more difficult.  We have already proven that electronic medical records save more lives than cause harm and the patient safety issues to exist and need to be evaluated but in their proper context.


The draft plan — called the Health IT Patient Safety Action & Surveillance Plan — recommends several strategies for the health IT industry to follow through 2015. Some of the strategies call for:

  • Establishing a code of conduct for health IT developers;
  • Supporting health care providers in their efforts to report adverse events;
  • Creating a forum for health IT users to compare their experiences;
  • Leveraging surveillance and testing opportunities available through ONC’s authorized accrediting bodies;
  • Incorporating health IT-related patient safety requirements into CMS’ health care facility safety standards;
  • Creating an ONC program to analyze data on health IT safety issues; and
  • Establishing a multi-agency HHS health IT safety panel.


The draft plan also calls for incorporating safety requirements into the meaningful use program’s criteria for the certification of electronic health record systems. Under the 2009 federal economic stimulus package, health care providers who demonstrate meaningful use of certified EHR systems can qualify for Medicaid and Medicare incentive payments (iHealthBeat, 2/6).

AMA’s Comments

The American Medical Association also commented on ONC’s draft plan, saying that the agency’s commitment to issuing guidance on health IT safety “will be very helpful.”

However, AMA called for additional research “on the impact of EHR use on patient safety in the ambulatory setting.”

The organization wrote, “Physicians are concerned about potential liabilities from EHR system design and software flaws, as well as lack of interoperability among EHR systems that could result in incomplete or missing information, which may lead to errors in patient diagnosis and treatment.”

TMA’s Comments

In its comment letter on the draft plan, the Texas Medical Association expressed concern that “the proposed plan lacks the specificity necessary for success.”

The letter stated, “TMA believes that significant patient risks exist now and new ones will emerge in the next one to two years as many EHR and other [health IT] vendors merge or go out of business.”

TMA recommended that ONC:

  • Immediately establish deadlines and processes for reporting patient safety issues;
  • Appoint a “highly visible [Health IT] Safety Czar” to promote patient safety across multiple health IT “programs, developers and end users;” and
  • Develop a single patient safety organization to receive reports of software problems, rather than the several regional PSOs called for under the draft plan (Modern Healthcare, 2/8).