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    June 3, 2019  
    Donald Rucker, MD
    National Coordinator
    Office of the National Coordinator for Health Information Technology
    Department of Health and Human Services
    Mary E. Switzer Building
    330 C Street SW
    Washington, DC 20201 
    RE: RIN 0955-AA01: 21st Century Cures Act: Interoperability, Information Blocking, and the ONC Health IT Certification Program 
    Dear National Coordinator Rucker: 
    Our organizations—which represent physicians, nurses, hospitals, public health professionals, and other stakeholders—encourage the Office of the National Coordinator for Health Information Technology (ONC) to prioritize patient safety as part of its efforts to implement new criteria for electronic health records (EHRs) used in the care of children.  
    Given that the care of children can differ significantly from that of adults, the technology used by clinicians should account for that variation. For example, children often receive medication doses based on their weight. Similarly, chronological or gestational age may be used for medication dosing in highly vulnerable premature infants. The EHRs used to prescribe those drugs should account for these critical dosing differences, which—coupled with the use of technology that is not geared towards these unique variations—can contribute to medical errors in pediatric care.  
    Safety problems associated with the use of EHRs in pediatrics often stem from system usability, which refers to how the technology can be effectively and efficiently used by clinicians. System layout, customizations, facility workflows, and many other factors can affect EHR usability for pediatric providers.  
    Poor usability can have significant negative consequences. It can contribute to clinician burden when using systems, which can harm the efficiency and quality of care. Poor usability can also contribute to medical errors. Research published in the November 2018 edition of Health Affairs showed that EHR usability contributed to medication errors in 3,243 of 9,000 safety events examined across just three health care organizations that care for children.1 Additionally, recent examples of EHR usability-related medical errors showcased pediatric-specific challenges, such as with newborn care and weight-based dosing.2 
    Recognizing this challenge, Congress—via the 21st Century Cures Act (Cures) passed in 2016— required ONC to establish voluntary certification criteria for EHRs used in pediatric settings. To implement this provision, the ONC proposed rule identifies 10 clinical priorities for pediatric care. ONC also included worksheets to map each of these clinical priorities to existing and proposed requirements for EHRs. For example, ONC proposes that EHRs used in pediatric care should have the ability to compute the weight-based dosage of a medication and could use EHR functions for electronic drug prescribing with pediatric vital signs to meet this clinical priority.  

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