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May 17, 2004

Jonathan C. Javitt, M.D.
Co-Chairman
President’s Information Technology Advisory Committee
Health Care Delivery and Information Technology Subcommittee
c/o National Coordination Office for Information Technology
Research and Development
4201 Wilson Boulevard, Suite II-405
Arlington, VA 22230
Dear Dr. Javitt:
HIMSS enthusiastically applauds the PITAC Health Care Delivery and Information Technology
Subcommittee’s work on the draft recommendations that were outlined at the PITAC meeting inApril, and again highlighted during your presentation at the May 4, 2004 HIMSS Government
Relations Roundtable luncheon. HIMSS looks forward to continuing our strong working
relationship with the Subcommittee and the rest of the PITAC on this issue of national
importance.
The Subcommittee’ recommendations are being very well received in the healthcare information
technology and management systems community. We strongly encourage the full PITAC tocontinue working through the remaining issues and release the recommendations, which could
lead the way to further federal support for the broader acceptance and use of electronic healthrecords (EHRs).
HIMSS appreciates the opportunity to offer additional comments on the draft recommendations.
In particular, we believe that one of the four bulleted “essential elements” needs furtherclarification. As written, this “essential element” states, “EHRs… maximize the amount of
information available to health care providers, while not creating new workflow or cost issues.”
Providers would welcome one interpretation of this guiding principle, that being, “EHR use
should not create unnecessary workflows or add costs for caregivers.” HIMSS believes that inmost instances, EHR use does create new workflows, and it is these new workflows that createvalue. These new workflows fall into three categories: collaborative sharing of information,administrative simplification, and transformative change.
Considering cost, adding information technology (hardware, software, connectivity) will always
add net cost, unless the technology increases practice efficiency or provider productivity, orenhances revenue. The EHR may add little or no net cost in a practice that is made more efficient
but adds no new services. In transformative implementations, however, the EHR will mostcertainly bring in new costs. But the overall benefits are sufficient to stimulate a realignment ofreimbursement to create a sustainable business case for information management. Ultimately,
this should return net savings to purchasers and payers.
HIMSS recommends the “essential element” on workflow and costs be revised to state, “EHRs(will) appropriately increase information available to caregivers, leading to new value-added
workflows, suggesting the creation of administrative efficiencies, and raising the potential for useof the EHR for a transformation of healthcare delivery. Workflow changes may result inHealthcare Information and Management Systems Societycontinued net costs to providers, particularly if their use of the EHR leads to the addition of newservices. These added costs must be covered through an equitable realignment ofreimbursement.” Additional justification for the recommended changes is outlined in the twopage attachment.
In addition, HIMSS is forwarding an analysis of the ICD-10 and SNOMED issue that wasprepared by our HIMSS member, Ms. Patricia S. Gibbons from Rochester, Minnesota.
We look forward to a continued dialog with the PITAC and helping further the implementation ofElectronic Health Records and other healthcare information and management systems solutions
throughout the U.S. healthcare system. Please do not hesitate to contact Mr. Thomas M. Leary,HIMSS Director of Federal Affairs, at 703.299.9712 or tleary@himss.org if you have additionalquestions.
Sincerely,

H. Stephen Lieber, CAE
President/CEOCc. Mr. Peter M. Neupert, Co-Chairman
David H. Staelin, Ph.D., Co-Chairman

Healthcare Information and Management Systems Society

Larry E. Dux, CPHIMS, FHIMSSChairman of the Board

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