BACKGROUND
The U.S. Department of Health and Human Services Office of National Coordinator for Health Information Technology has proposed a new regulation that would require electronic health record systems to document and use disaggregated, granular data categories for patients’ race, ethnicity, and language, and document and use patients’ sexual orientation, gender identity, and social and behavioral factors that influence health status. Having such demographic data will identify health care disparities and advance health equity. The regulation would require up to 900 race and ethnicity categories and up to 600 language categories, which is the first time that there would be comprehensive disaggregation and complete granular categories required by any federal department. This also would be the first time that sexual orientation and gender identity data would be routinely collected, although these data would still be voluntary and there are some technical problems with the proposed categories.
ACTION NEEDED
Public comments supporting this proposed regulation are needed. While comments submitted by organizations are important, it also is very important for individual members of the public to submit personalized comments. Please submit your comments online no later than 5pm EST on May 29, 2015 at:
http://www.regulations.gov/#!documentDetail;D=HHS-OS-2015-0005-0001
KEY MESSAGES
I support the proposed regulation requiring electronic health record systems to document disaggregated, granular data categories for patients’ race, ethnicity, and language.
As a patient and individual concerned about health equity and reducing racial and ethnic health care disparities, it is essential that disaggregated, granular data about race, ethnicity, and language be documented in electronic health records to be used to improve the quality of health care and to reduce health care disparities.
I also support the proposed regulation requiring electronic health record systems to document patients’ sexual orientation, gender identity, and social and behavioral factors that influence health status, and support making these requirements mandatory for all electronic health record systems. I also support technical changes in the proposed categories for sexual orientation and gender identity consistent with the recommendations of lesbian, gay, bisexual, and transgender health care providers and community advocates.
As a patient from [or ally of] the lesbian, gay, bisexual, and transgender communities, it is very important to me that my health care providers can document this demographic information in my electronic health record and can use that information to reduce health care disparities among lesbian, gay, bisexual, and transgender populations.
U.S. Department of Health and Human Services Office of National Coordinator for Health Information Technology, Notice of Proposed Rulemaking for 2015 Health Information Technology Certification Criteria, 80 Fed. Reg. 16804-16921 (March 30, 2015)
Ignatius Bau 