May 28, 2024 Micky Tripathi, PhD, MPP Office of the National Coordinator for Health Information Technology (ONC-HIT) U.S. [...] Tripathi: The American Psychiatric Association (APA), the national medical specialty society representing over 38,900 psychiatric physicians and their patients, appreciates the opportunity to comment on the Draft 2024-2030 Federal Health IT Strategic Plan. [...] To help achieve the goals outlined, APA suggests ONC provide clear governance models and informed consent mechanisms to guide providers, and which are essential for secure data exchange. [...] Data privacy, including informed consent, needs to be considered given the need for increased integration of rural healthcare facilities, variability of existing IT systems and ever-changing digital health landscape. [...] APA suggests that: • To protect patients’ online mental health data and safety, data privacy and patient protection frameworks need to be updated frequently with the involvement of pertinent stakeholders. • Data privacy standards should apply to any platform that hosts sensitive health-related data, particularly related to mental health and substance use. If HIPAA standards are not met, a [...] • Treatment-focused apps must adopt high standards of evidence-based practice and can function as a supplement to mental health care but are not a substitute for care delivered by a licensed mental health clinician for clinically significant mental illness. Integrating behavioral health data with primary care and addressing this integration gap is also crucial for seamless data exchange and [...] This could facilitate secure data exchange between mental healthcare apps, wearables and other health IT systems, including electronic health records (EHRs). Addressing this gap means it is alsocritical for use of telemedicine, including video conferencing and audio-only care, to become an essential strategy to improve health equity and increase access to high-quality care. [...] For instance, APA urges ONC to include asynchronous care in its strategic plan ensuring reimbursement for mental healthcare services for those with serious mental health issues and those with disabilities. Moreover, data components from the homeless management information system (or integration of) should be considered. [...] ONC should keep in mind the existence of digital literacy gap especially within marginalized groups and APA encourages ONC to develop funding and technical assistance mechanisms to reduce the disparity for patients/consumers as well as physicians. Additionally, APA urges ONC to consider smaller and rural behavioral health organizations who may face resource limitations in adopting and mai [...] As it stands, current grants are short term, and the development of health IT is different from other grants and those differences should be considered.
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