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  • ACOEM Urges Inclusion of Industry/Occupation Information for Certification in Meaningful Uses Stage 3

    May 29, 2015

    Office of the National Coordinator for Health Information
    Hubert H. Humphrey Building, Suite 729D
    200 Independence Ave, SW
    Washington, DC 20201

    Attention: 2015 Edition Health IT Certification Criteria Proposed Rule

    To Whom It May Concern:

    On behalf of the American College of Occupational and Environmental Medicine (ACOEM), I am writing in strong support of the inclusion of industry and occupation (I/O) information for certification in Meaningful Use Stage 3.

    ACOEM, an organization of more than 4,000 occupational physicians and other health care professionals, provides leadership to promote optimal health and safety of workers, workplaces, and environments.

    ACOEM agrees with the ONC’s statement in the Notice of Proposed Rulemaking (NPRM) that “the combination of industry and occupation (I/O) information provides opportunities for health care providers to improve patient health outcomes — for health issues wholly or partially caused by work and for health conditions whose management is affected by work.”

    Electronic health records (EHRs) for general group health have not typically incorporated easy approaches to documenting an occupational history — despite clear evidence that such data can be critically important for quality care in almost any medical field. 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 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.

    For additional background on the magnitude of this opportunity and the likelihood that capturing such data in Electronic Health Records or Health IT systems will benefit the American workforce and public health generally, please see the attached ACOEM
    paper, General Health Electronic Health Records (EHRs) and Occupational Elements: A Call for New Meaningful Use Criteria.

    In the Federal Register at 80 FR 16830, the ONC solicits comments from health care providers and provider organizations on several questions. Following are ACOEM’s responses to several of these questions.

    • The usefulness for providers to be able to access current and usual I/O and related data in the EHR, including whether additional data elements, such as work schedule, are useful.

    Response: ACOEM believes it is very important for medical providers to able to view a patient’s I/O, including work schedule. In practical terms, the I/O information is simple to obtain, and should include the narrative or text field in chronological order so the health care provider can readily understand the current and usual occupations.

    • The usefulness of a history of positions provided as current I/O, with data from each position time-stamped, linked, retained, and accessible as part of the longitudinal patient care (medical) record.

    Response: ACOEM recommends that a readily accessible field be provided to allow the provider to enter current occupation as free text. Additional functionality within the Health IT system could then optionally permit a drill-down to a more specific occupation code, if the provider should need to capture such additional detail. The EHR should date-stamp the text entry, in order to facilitate reconstruction of the longitudinal work history at a future time.

    • Narrative text (vs. codes) for both current and usual I/O.

    Response: For simplicity, ACOEM favors entry of “current occupation” as plain text. This approach significantly reduces provider burden. However, for epidemiological purposes, coding is essential. We understand that NIOSH has developed autocoding software which can efficiently and with sufficient accuracy translate plain text into CDC census codes.

    Thank you for your consideration of these comments. Please contact Patrick O’Connor, ACOEM’s Director of Government Affairs, if you have additional questions or need additional information He can be reached at 202-2236222 or by e-mail at patoconnor@kentoconnor.com.


    Mark A. Roberts, MD, PhD, MPH, FACOEM