Category Archives: HIE

Oct 13 FAQ Updates for State HIE Cooperative Agreement by ONC

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ONC Updates FAQs on HIE Cooperative Agreement
Frequently Asked Questions Updated as of October 13, 2009
Application FAQs were updated on Oct 13, 2009, and Funding FAQs were updated Oct 9, 2009. ONC encourages users to check its site frequently for updates.
Main HIE Cooperative Agreement FAQ page
          Background FAQs Updated 10/5/09
          Application FAQs Updated 10/13/09
          Funding FAQs Updated 10/9/09
          Award Administration FAQs Updated 10/5/09

Many of the latest additions to the FAQs appear to involve the nitty-gritty of  uploading the documents via Grants.gov, including a size limit of 250 megabytes for the TOTAL PACKAGE and formatting concerns. It also appears, with the deadline looming on Friday, October 16, 2009  (5:00PM SET), applicants are recognizing gaps in their plans, timing, and compliance issues. The FAQs work to identify and answer these questions with specific directions.

Please check the ONC pages for the full HIE Agreement FAQs.

University of Central Florida: Regional Extension Center Applicant

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University of Central Florida College of Medicine seeks stimulus money for medical records
In the first story I’ve seen published on an applicant who received preliminary approval from ONC to be a regional extension center, Fernando Quintero, Orlando Sentinel, reported on October 12, 2009, that the College of Medicine of University of Central Florida has been asked to file a full application by November 3, 2009 in the first of three waves. According to the story, UCF will be eligible for an $8,000,000 grant which is the about the average grant amount expected to be awarded.

In a strong approach to demonstrating stakeholder support, UCF is working to obtain 1,200 letters of support from medical providers by October 27, 2009. Jeannette Schrieber, associate dean of special projects at UCF said “”Our biggest challenge now is to get our local doctors on board with this and build their trust.”

Recent post on e-Healthcare Marketing about update of FAQs on Regional Extension Centers grants program submissions.

If you come across any other published stories on preliminary approval for regional extension centers, please let me know via comments or emailing me at address in “About” link. Thank you.

Aetna, Blue Cross & Blue Shield, UnitedHealthcare sharing patient data in CT

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Aetna, UnitedHealthcare, Anthem Blue Cross and Blue Shield of Connecticut, ConnectiCare, Health Net of the Northeast
to provide patient data for health information exchange
Greg Bordonaro of Hartford Business reported October 12, 2009, “Five of the state’s largest health insurance companies and the Centers for Medicare & Medicaid Services (CMS) have begun to aggregate some of their patient data and share it with Connecticut physicians as part of a new venture that aims to improve quality care in the state.”

The Connecticut Health Quality Cooperative with these insurance companies was formed by eHealth Connecticut, which was designated a Chartered Value Exchange by AHRQ in 2008. CHQC, according to an eHealth Connecticut presentation given at New England HIMSS Public Policy Forum in May 2009,  was setup to “Provide physicians with aggregated and standardized performance data to improve quality and efficiency of care for all patients.”  Per that presentation,claims-based measures from Medicare and health plan HEDIS to be used include:  Diabetes tests (A1c, Lipid, eye exams),  CAD/HTN (Lipid), Prevention (mammography, PAP); Asthma (medications), and Efficiency (Rx/tests for children with URIs or pharyngitis, respectively.)

Presentations at New England HIMSS Public Policy Forum, May 2009
4th Annual Public Policy Forum: “The Perfect Storm for Healthcare Reform” Download Library

eHealth Connecticut: “Statewide Health Information Exchange:
Turning Hype into Real Projects” (pdf)
Presented by Scott Cleary, Program Director, eHealth Connecticut

eHealth Connnecticut, designated the state’s official Health Information Exchange, according to Hartford Business, also recently joined forces with THICC (Transforming Healthcare in Connecticut Communities), a coalition of 20 hospitals, physician practices, employer groups, and insurers forming their own health information exchange.

THICC: See a September 1, 2009 story by Eric Wicklund in Healthcare IT News about the EHR setup from Allscripts that hospitals and physician organizations in THICC will subsidize.

Lab Data spotlight at HIT Policy Committee

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Laboratory Information spotlight at HIT Policy Committee/
Information Exchange Workgroup Hearing Oct 20, 2009
Per the Federal Register Oct 6, 2009 notice, ”The (HIT Policy Committee’s Information Exchange) Workgroup will be hearing testimony from invited experts and stakeholders in the area of electronic exchange of  laboratory information.” The function of the Workgroup is “To provide recommendations to the National Coordinator on a policy framework for the development and  adoption of a nationwide health information technology infrastructure that permits the electronic exchange and use of health information as is consistent with the Federal Health IT Strategic Plan and that includes recommendations on the areas in which standards, implementation specifications, and certification criteria are needed.

“The Information Exchange Workgroup is charged with making recommendations to the HIT Policy Committee on issues related to policies, governance, sustainability, and architectural approaches to enable health information exchange.”

The College of American Pathologists sent comments to ONC on June 26, 2009 (pdf) about the need to recognize the role  pathologists play in lab information, and how that role should impact the ”Meaningful Use” matrix. As of June, the comments stated “the draft matrix does not take into consideration that pathologists do not typically have access to the patient’s health record, including EHR’s and personal health records (PHR), hampering the ability of the pathologist to access all the clinical information necessary to determine appropriate testing, test interpretation and follow-up.”

Federal Register Notice
HIT Policy Committee Upcoming Meetings
           October 20, 2009: 9am to 3pm
           The Omni Shoreham Hotel
           Washington DC

ONC releases patient data ‘preferences’ draft, Comments due Oct 16, 2009

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ONC releases patient data ‘preferences’ draft:
Public Comment is due Friday, Oct 16, 2009
Joseph Conn, HITS staff writer for Modern Healthcare, broke the story on ONC’s draft document on consumer preferences for personal data included in electronic health records for information exchange on October 7, 2009.  Public comment is due Friday, October 16, 2009.  As Conn reports “HHS’ Office of the National Coordinator for Health Information Technology has released for public comment a 42-page draft document intended to ultimately guide and perhaps even control healthcare organizations in how patients’ can express their “preferences” on the use of their medical records and healthcare data.” Conn provides context for the draft.

The draft says “This Requirement Document is focused on information needed to facilitate the electronic exchange of consumer preferences regarding the use and management of their associated needs.”

This document is made up of nine sections including scenarios and process diagrams.
Excerpted from draft:
Section 1.0, Preface, includes a Requirements Document Review Guidance, that indicates who the end users of this document are intended to be and what sections may be most relevant to these various end users. Additionally, this section outlines the amended approach utilized to develop the Requirements Document, describes the sections of the document and denotes any significant changes from previous Use Cases.

Section 2.0, Introduction and Scope, describes the background, progress to date, the request being made to HITSP and the scope of that request.

Section 3.0, Stakeholders, lists the individual stakeholders and organizations that participate in the activities described in this Requirements Document.

Section 4.0, Issues and Policy Implications, describes issues, obstacles and policy considerations and/or implications related to accommodating and supporting consumer preferences.

Section 5.0, Perspectives & Scenarios, describes the perspectives/roles of the stakeholders participating in the events and actions of the underlying scenarios that are supported by the process diagrams and information exchanges described in later sections.

Section 6.0, Process Diagrams, depicts the business processes surrounding consumer preferences that may or may not involve health information exchange; the process diagrams are described in the Events and Actions component of this section.

Section 7.0 Information Exchanges; depicts the focused information exchanges that standards development organizations should address.

Section 8.0, Functional Needs, describes the combination of end-user needs and system behaviors that support interoperability and information exchange.

Section 9.0, Data Set Considerations, provides a comprehensive (though not exhaustive) framework that can be used to support standards development and to accommodate the major types of consumer preferences.

Appendix A, Glossary, provides contextual descriptions of key concepts and terms introduced in this Requirements Document.

ONC’s Consumer Preferences Requirements Document Page
      Consumer Preferences Draft Requirements Document (pdf)
      Feedback Instructions

The draft and public feedback is being managed by ONC’s Requirements Documents Team.

For information on HITSP eTown Hall Webinar about Document on October 13, 2009, see later post on e-Healthcare Marketing.

ONC updates FAQs on HIE Coop: Oct 5-6, 2009

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ONC Updates FAQs on HIE Cooperative Agreement
Frequently Asked Questions Updated as of October 6, 2009
All four sections were updated the week of October 5, 2009. ONC encourages users to check its site frequently for updates. Additional updates 10/9 and 10/13.
Main HIE Cooperative Agreement FAQ page
          Background FAQs Updated 10/5/09
          Application FAQs Updated 10/13/09
          Funding FAQs Updated 10/9/09
          Award Administration FAQs Updated 10/5/09

 The FAQs reemphasize that the total allocation by state is not dependent on whether the state is in the planning or implementation stage, but the timing of the release of funds will depend on approval of the state’s strategic and implementation plans by ONC. Timing does impact requirements for matching funds by the states.

In addition ONC explained the recent elimination of the needs based allocation from the funding formula. Each state and territory  will receive a base payment of $4 million plus an equity factor for states and DC and Puerto Rico, based on number of primary care physicians per state, number of short stay hospitals in the state, medically underserved  and rural populations (federally qualified health centers and rural health centers), and state population.

The sources for data impacting equity factors in funding allocations are also provided in the Funding FAQs.

Please check the ONC pages for the full HIE Agreement FAQs.

NJ Posts Framework for HIE Application to ONC

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New Jersey Posts Framework for HIE Application to ONC
At the New Jersey HIT Commission meeting on October 1, 2009, the state presented the preliminary framework for its proposal to Office of National Coordinator (ONC) for the State Health Information Exchange (HIE) Cooperative Agreement Program application (pdf).
Presentation  (pdf)
NJ HIT Commission Page: http://www.nj.gov/health/bc/hitc.shtml

The preliminary framework does not yet show how the specific HIE grant proposals made by New Jersey organizations to the state will be folded into the framework for the proposal to ONC. It was noted at the commission meeting that a new board, separate from the commission, would be established to govern the NJHIE. The commission would provide standards and guidance for the NJHIE board.

Several other key points in the framework include:
–Planned used cases include Accurate Patient Identification, State Databases, ePrescribing, Lab Results, Clinical Messaging Services to Provider Portals, Emergency Department/Hospital Discharge Summaries; and Chart Summaries and Radiology Reports to Emergency Departments/Hospitals/SNFs, Physicians and Clinics.
–Hybrid technology approach.
–NJHIE will provide gateway for Community HIE’s to access the national NHIN and gateway between NJ Community HIEs.
–A single Community HIE (designated NJ‐CHIE) should be developed or sponsored by the agency that operates the NJHIE. This “default,” Community HIE would provide connections for entities that have no other way to connect, and would be operated, at least on an interim basis, as an adjunct capability of the NJHIE.
–NJHIE will provide statewide Master Patient Index (MPI).
–Privacy and Security Standards.
–Kurt Salmon and Associates is updating environmental scan on HIE from NJHA plan they produced in 2007.

Presentations from Rutgers and a survey of CIOs by NJ HIMSS were also presented at the Commission meeting.

Work Begins on National E-Health Record Network

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AP: Work Begins on National E-Health Record Network
KANSAS CITY, Mo. (AP) — (Sept 30, 2009) “Doctor’s offices and hospitals have slowly started the difficult switch from outmoded paper records to sophisticated electronic systems in a bid to improve care and cut costs.” David Blumenthal, National Coordinator for Health Care IT reiterates federal commitment to innovation in private industry ”fully expect(ing) there will be a lot of different solutions to the exchange problem.” While this is not real news inside the industry, this is an initial stage of a concerted communications initiative to get the word out to the public.

HIT Policy Committee’s Recommendation Letters to National Coordinator for Health IT

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HIT Policy Committee’s “Letters of Transmittal” Recommendations to National Coordinator for Health IT
from August and July 2009 Meetings
Policy Transmittal Letters site
“The HIT Policy Committee, a federal advisory committee, provides recommendations on HIT policy issues to the National Coordinator for his consideration. The National Coordinator is also the Chair of the HIT Policy Committee, and, therefore, a formal transmittal letter must transmit the recommendations from the Policy Committee to the National Coordinator in his role as an HHS official. Once the FACA has been satisfied (i.e., a transmittal letter sent from the Committee to the National Coordinator in his governmental role), the National Coordinator can then determine the disposition of the recommendations.”

August 14, 2009 Policy Committee Meeting Transmittal Letter
PDF version          HTML Excerpted from ONC site pasted below:

David Blumenthal, MD, MPP
National Coordinator for Health Information Technology
Department of Health and Human Services
Washington, DC

Dear Dr. Blumenthal:

The HIT Policy Committee (the Committee) is charged with recommending to the National Coordinator a policy framework for developing and adopting a nationwide health information technology infrastructure for the electronic exchange and use of health information technology. Therefore, the Committee is submitting to you recommendations that we finalized at our August 14, 2009, Committee meeting. At that meeting, the Committee heard presentations and received advice on a variety of topics from two of its Workgroups, the Certification/Adoption Workgroup and the Information Exchange Workgroup. After considerable discussion of those presentations and the Workgroups’ input, the Committee agreed upon several recommendations, as described below.

The Certification/Adoption Workgroup’s presentation pertained to certification criteria for electronic health records (EHRs) which are specified in the American Recovery & Reinvestment Act (ARRA) of 2009, and certain EHR functional requirements that support Meaningful Use objectives.

As background, ARRA authorized the Centers for Medicare & Medicaid Services (CMS) to provide a reimbursement incentive for eligible professionals and hospital providers who are “meaningful users” of certified electronic health records (EHRs). This incentive payment is anticipated to begin in 2011 and gradually decrease through 2014, after which providers are expected to have adopted and be actively utilizing an EHR in compliance with the “meaningful use” definition or they will be subject to financial penalties.

The Committee discussed the Workgroup’s advice and reached several important decisions regarding a certification process, expansion of the process to improve its objectivity and transparency, and a proposed short-term certification transition plan. Based in part on the Workgroup’s input, the Committee is submitting to you for your consideration the following.

RECOMMENDATIONS

We recommend that in defining the certification process for an electronic health record (EHR), the following objectives are pursued:

1. Focus certification on Meaningful Use.

2. Leverage the certification process to improve progress on privacy, security, and interoperability.

3. Improve the objectivity and transparency of the certification process.

4. Expand certification to include a range of software sources, e.g., open source, self-developed, etc.

5. Develop a short-term certification transition plan.

The second set of recommendations originated from the Committee’s Information Exchange Workgroup. During the August 14th meeting, the Committee considered the Workgroup’s input, which focuses on those Meaningful Use objectives that require health information exchange. After lengthy discussion, the Committee decided on the following four high-level recommendations as they relate to health information exchange, and are submitting them to you.

RECOMMENDATIONS
1. Information exchange requirements: The core information exchange requirements must be technology- and architecture-neutral, and apply to all participants seeking to demonstrate meaningful use to the Centers for Medicare & Medicaid Services (CMS).

2. Core requirements: Consistent with the recommendations of the Certification/Adoption Workgroup, these core requirements should be focused on the capability to achieve meaningful use and include interoperability, privacy, and security.

3. Certification of interoperability components: The federal government should certify EHR and health information exchange components on these core requirements to ease the burden on eligible professionals and hospitals for meeting and demonstrating adherence with meaningful use requirements.

4. Aligning federal and state efforts and bringing existing efforts into alignment: Federal and state-government approaches should be complementary, and grants to states should require alignment with federal meaningful use objectives and measures.

The Committee recommends that the National Coordinator accept (1) its Recommendations on certification and the certification process, and (2) its Recommendations focusing on those Meaningful Use objectives that require health information exchange. Further, the Committee requests that the National Coordinator recommend to the Secretary that the appropriate operating and staff divisions (OP/STAFFDIVs) within the Department be directed to consider how best to address and/or implement the Recommendations.

We fully appreciate your Office’s and the Department’s leadership role and efforts to advance widespread adoption of interoperable health information technology in the United States.

Sincerely,

Paul Tang
Vice Chair Health IT Policy Committee

July 16, 2009 Policy Committee Meeting Transmittal Letter
PDF version          HTML Excerpted from ONC site pasted below:

August 10, 2009

David Blumenthal, MD, MPP
National Coordinator for Health Information Technology  
Department of Health and Human Services
Washington, DC

Dear Dr. Blumenthal:

The Health IT Policy Committee (the Committee) received a number of recommendations from its Workgroups during the July 16, 2009, Committee meeting. The first recommendation, which came from the Meaningful Use Workgroup, pertains to the definition of “meaningful use,” and focuses on improved health outcomes and efficiency as demonstrated through the meaningful use of certified electronic health record (EHR) technologies. During that meeting, the Committee considered the recommendation and decided to adopt it as its own.

As background, the American Recovery and Reinvestment Act of 2009 authorized the Centers for Medicare & Medicaid Services (CMS) to provide a reimbursement incentive for eligible professionals and hospitals who are “meaningful users” of certified electronic health records (EHRs). This incentive payment is anticipated to begin in 2011 and gradually decrease through 2014, after which providers are expected to have adopted and be actively utilizing an EHR in compliance with the “meaningful use” definition or they will be subject to financial penalties.

As we understand, CMS intends to publish a proposed rule in the next 12 months to propose a definition of meaningful use of certified Electronic Health Records (EHR) technology and establish criteria for the incentives programs. We have been informed that CMS is working with the Office of the National Coordinator (ONC) to identify the proposed criteria. Consequently, the work of the HIT Policy Committee serves an advisory purpose, and will hopefully lay a foundation for the policies, which as we understand, will be proposed by the Secretary and subject to public comment.

The ultimate goal of meaningful use of an EHR is effective use and exchange of electronic health information to improve health care and manage chronic disease while decreasing costs and inefficiencies. However, this will be a gradual process that will require time, education, workflow redesign, and seeks to improve the delivery of medical care. In order to achieve widespread use of health information technology, it is important to start with a basic set of features and capabilities focusing on data collection and build on these capabilities that can become the basis for improved performance in subsequent years.

The Committee reached several important decisions regarding the definition of meaningful use, progressing from a focus on process to achieving measurable outcomes that support patient engagement and improved care coordination. Five health outcomes are prioritized for consideration by the National Coordinator and ultimately for the Department of Health and Human Services (HHS): improve quality, safety, efficiency, and reduce health disparities; engage patients and families; improve care coordination; improve population and public health; and ensure adequate privacy and security protections for personal health information.

RECOMMENDATION

We are submitting to you as our Recommendations the attached matrix for your consideration and possible consideration by the Department of Health and Human Services (HHS) in defining “meaningful use” of an electronic health record (EHR).

The second set of recommendations originated from the Committee’s Certification/Adoption Workgroup. During the July 16th meeting, the Committee considered the recommendations, which focus on improving the certification process to ensure that a system is able to achieve government requirements for security, privacy, and interoperability, and that the system would enable the Meaningful Use results that the government expects.

After lengthy discussion, the Committee accepted the following high-level recommendations as they relate to certification and are submitting them to you as our recommendations.

RECOMMENDATIONS

1. Focus certification on meaningful use.

2. Leverage the certification process to improve progress on security, privacy, and interoperability.

3. Improve the objectivity and transparency of the certification process.

4. Expand certification to include a range of software sources: open source, self-developed, etc.

5. Develop a short-term transition plan for the certification process.

The Committee recommends that the National Coordinator accept its Recommendation on “meaningful use,” and its Recommendations on Certification, and further request that the Secretary direct the appropriate operating and staff divisions (OP/STAFFDIVs) within the Department to consider how best to address the Recommendations.

We fully appreciate your Office’s and the Department’s leadership role and efforts to advance widespread adoption of interoperable health information technology in the United States.

Sincerely,

Paul Tang
Vice Chair Health IT Policy Committee

Attachment: Matrix on Meaningful Use Objectives and Measures (pdf)

See HIT Standards Committee’s Formal Recommendations on e-Healthcare Marketing.

HIT Standards Committee’s Recommendations Letter to Office of National Coordinator for Health IT

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HIT Standards Committee’s “Letter of Transmittal” Recommendations to Office of National Coordinator for Health IT
from August 2009 Meeting
Standards Transmittal Letters site
“The HIT Standards Committee, a federal advisory committee, provides recommendations on HIT standards issues to the National Coordinator for his consideration. Therefore, a formal transmittal letter must transmit the recommendations from the Standards Committee to the National Coordinator in his role as an HHS official. Once the FACA has been satisfied (i.e., a transmittal letter sent from the Standards Committee’s Chair to the National Coordinator in his governmental role), the National Coordinator can then determine the disposition of the recommendations.”

August 20, 2009 Standards Committee Meeting Transmittal Letter
with attachments linked below
PDF version         HTML Excerpted from ONC site pasted below:

David Blumenthal, MD, MPP
National Coordinator for Health Information Technology Office
Department of Health and Human Services Room
Washington, DC

Dear Dr. Blumenthal:

The Health IT Standards Committee (the Committee) is charged with making recommendations to the National Coordinator on standards, implementation specifications, and certification criteria for the electronic exchange and use of health information, and with respect to certain topics, in accordance with policies developed by the HIT Policy Committee. Therefore, the Committee is submitting to you recommendations that we finalized at our August 20, 2009, Committee meeting. At that meeting the Committee heard presentations and received advice on a variety of topics from three of its Workgroups, the Clinical Quality Workgroup, the Clinical Operations Workgroup, and the Privacy and Security Workgroup. After considerable discussion of the presentations and the Workgroups’ input, the Committee agreed upon several recommendations, as described below.

The Clinical Quality Workgroup’s presentation pertained to the appropriate standardized performance measures that correspond to the HIT Policy Committee’s 2011 Meaningful Use Measures. The Clinical Quality Workgroup presented 30 quality performance measures and the data types required for each, of which they identified the National Quality Forum (NQF)-endorsed measures which can either be retooled for use in an Electronic Health Record (EHR) or will require attestation for the foreseeable future. As noted on the attached Meaningful Use Measure Data Element Grid, specific content and vocabulary standards were selected on all but six data elements.

The Committee discussed the Workgroup’s advice and reached several important decisions regarding the appropriate quality measures for the 2011 Meaningful Use Measures, and voted to accept the Meaningful Use Measure Data Element Grid as recommendations to the National Coordinator for Health Information Technology. Based in part on the Workgroup’s input, the Committee is submitting to you for your consideration the following:

RECOMMENDATIONS

We are submitting to you as our Recommendations the attached “HIT Standards Committee Meaningful Use Measure Data Element Grid” for your consideration and possible consideration by the Department of Health and Human Services (HHS) as standards and certification criteria are developed.

The second set of recommendations originated from the Standard Committee’s Clinical Operations Workgroup (Operations WG). As background, during the July 21, 2009, Standards Committee meeting, the Operations WG presented descriptions, documentation, and initial recommendations on standards for 2011 Meaningful Use, which were accepted by the Committee. Then, during the August 20, 2009, Committee meeting, the recommendations on standards for 2011 Meaningful Use were accepted as outlined in the July 21st meeting, and an additional recommendation on quality measure reporting was added to round out the standards to support 2011 Meaningful Use criteria.

After lengthy discussion, the Committee decided on the content and vocabulary standards supporting Meaningful Use for 2011 as well as a gradual transition plan to 2013 per the attached “Summary of Clinical Operations Workgroup Recommendations.” The recommendations include messaging formats and all the vocabularies necessary for semantic interoperability, and the Committee is submitting them to you as our recommendations.

RECOMMENDATIONS

We are submitting to you as our Recommendations the attached “Summary of Clinical Operations Workgroup Recommendations: for Definitive 2011 and 2013 Implementation” for your consideration and possible consideration by the Department of Health and Human Services (HHS) as standards and certification criteria are developed.

The third set of recommendations originated from the Standard Committee’s Privacy and Security Workgroup (P&S WG). The P&S WG recommended authentication, authorization, auditing and secure data transmission standards for consideration by the Committee. The Meaningful Use measures recommended by the P&S WG include: measures representing value that EHR adoption can contribute to an enterprise’s HIPAA compliance; measures representing changes in approach to HIPAA compliance resulting from EHR adoption; and measures that can be objectively assessed by HHS.

After discussion, the Committee decided on all of the privacy and security standards applicable to Meaningful Use of an EHR per the “Privacy and Security Standards Applicable to ARRA Requirements.” The Committee is submitting them to you as our recommendations.

RECOMMENDATIONS

We are submitted to you as our Recommendations the attached “Privacy and Security Standards Applicable to ARRA Requirements” for your consideration and possible consideration by the Department of Health and Human Services (HHS) as standards and certification criteria are developed.

We fully appreciate your Office’s and the Department’s leadership role and efforts to advance widespread adoption of interoperable health information technology in the United States.

Sincerely,

Jonathan Perlin
Chair, Health IT Standards Committee

Attachments (3):
“HIT Standards Committee Meaningful Use Measure Data Element Grid” (pdf)
“Summary of Clinical Operations Workgroup Recommendations” (pdf)
“Privacy and Security Standards Applicable to ARRA Requirements”(pdf)

See HIT Policy Committee’s Formal Recommendations on e-Healthcare Marketing.