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  • ACOEM Urges Inclusion of Occupational Health Data in Proposed Stage 3 List for Electronic Health Records

    October 9, 2012

    Farzad Mostashari, MD, ScM
    National Coordinator for Health Information Technology
    U.S. Department of Health and Human Services
    200 Independence Avenue S.W.
    Suite 729-D
    Washington, D.C. 20201

    Dear Dr. Mostashari:

    On behalf of the American College of Occupational and Environmental Medicine, I am writing to bring to your attention the value and need for the inclusion of occupational health data (OHD) in the proposed Stage 3 list of meaningful use criteria for electronic health records (EHRs).

    Although many vendors have developed specialized EHR systems for occupational medicine, EHRs for general group health have not typically included features related to a patient’s work life, such as data fields to code a patient’s occupational risks or work capacity – despite clear evidence that such data can be critically important for quality care in almost any field of medical practice.

    Approximately 140 million Americans are employed. Their health can affect their ability to work safely and productively, and in turn their jobs can affect their health. A basic knowledge of a worker’s job duties and hazards can be invaluable to all physicians in order to recognize and treat work‐related conditions and to prevent injury and illness in other workers. Furthermore, a physician’s knowledge of a patient’s job duties is foundational for facilitating a prompt and safe return to work. Finally, incorporating basic occupational demographic information into all EHRs could make important contributions to public health practice and research.

    As outlined in the attached paper, EHRs should capture data about patients’ job duties, occupational hazards, and functional status. Also, because providers are often required to exchange occupational information with many stakeholders, ACOEM further recommends, subject to complex legal restrictions, that the anticipated Stage 3 meaningful use criteria for EHRs include new software functionalities to facilitate sharing of such occupational information.

    ACOEM proposes six new meaningful use criteria related to occupational health which we believe all EHR systems should meet in order to optimize medical care and improve the health of American workers. The EHRs should:

    1. include standardized fields to capture a patient’s functional capacity and work status, with a required minimum set of data elements;
    2. record and retain the patient’s current or usual occupation when working, preferably using the Standard Occupational Classification (SOC) code, as well as the current employer and the employer’s industry code using the North American Industrial Classification System (NAICS), and the date of the recording, all in a searchable database;
    3. record certain sentinel occupational exposures or risk factors on the problem list, with a capability to use these sentinel risks for later clinical management and decision support;
    4. have the capacity to exchange secure context‐specific “messages” (including legally mandated forms used in state workers’ compensation systems and federally required medical examinations) with credentialed stakeholders;
    5. be able to exchange specified data elements that are relevant to occupational safety and health, including health risk appraisals (HRAs) with personal health record (PHR) systems; and
    6. allow for adjustable firewalls that permit certain EHR users to see only a select subset of fields.

    ACOEM urges ONC to consider including these criteria into the proposed Stage 3 list of meaningful use criteria and recommends that software vendors begin incorporating these capabilities into their EHR systems.

    Please do not hesitate to contact me or Pat O’Connor, ACOEM’s Director of Government Affairs, at 202-223-6222, should you have any questions regarding the concerns outlined above or this matter in general.

    Thank you for your consideration of our comments. We welcome the opportunity to meet with you and your staff to discuss this important matter in detail.


    Karl Auerbach, MD, MS, MBA, FACOEM

    Encl.: ACOEM Opinion Paper: General Health Electronic Health Records (EHRs) and Occupational Elements: A Call for New Meaningful Use Criteria