AMA submission on Personally Controlled Electronic Health Record System: Draft Concept of Operations

The AMA submission on the proposed PCEHR expresses concerns that the proposed form of the PCEHR will provide only limited safety benefits and these are significantly outweighed by its inherent clinical and medico-legal risks for medical practitioners and the administrative burden it will impose on medical practices.

The AMA submission advocates for:

• a shared electronic medical record (that sits within a personally-controlled electronic health record) that contains reliable and relevant medical information about individuals that has been posted by medical practitioners;
• health consumer participation in the PCEHR to be opt-out.  An opt-in system will mean that doctors eventually give up looking for PCEHRs after failing to find them for other patients; and
• system protocols that align with clinical workflows and integrate with existing medical practice.

The submission highlights that the proposed PCEHR:

• will be extremely complex to use because it is built around exceptions to clinician access and input to the record;
• allows health care providers who are not medical practitioners to upload information;
• allows patients to hide key pieces of medical information, thus compromising its usefulness to medical practitioners;
• creates significant exposure to medico-legal liability for participating medical practitioners;
• must not impose penalties on medical practitioners if they do not use the PCEHR; and
• imposes significant administrative and financial burdens on participating medical practitioners and practices.

The submission concludes that the cumulative effect of these points will mean that medical practitioners are unlikely to use the PCEHR in the form proposed.