[humanser] Resolution 2014-10 Regarding the Omission of Accessibility Standards in the Office of the

[Mary Ann Robinson]

I want to thank everyone for working so hard to pass the following resolution.



Mary Ann Robinson



Resolution 2014-10

Regarding the Omission of Accessibility Standards in the Office of the

National Coordinator for Health and Information Technology's Certification

Criteria for Electronic Health Records

WHEREAS, the transition from print-based medical records to electronic

health records (EHR) offers the opportunity to expand the circle of

participation in the healthcare industry by giving blind providers

mainstream access to systems and material that they need in order to do

their jobs without the need for alternative formats, specialized services,

and customized supports, and by giving blind patients private and equal

access to their health records; and

 WHEREAS, most current EHR technology is inaccessible to blind people working

in or pursuing work in the healthcare industry, creating new barriers that

may ultimately drive blind people out of the industry altogether; and

WHEREAS, the Office of the National Coordinator for Health and Information

Technology (ONC), which is housed in the Department of Health and Human

Services, drives the market for EHR technology by developing Certification

Criteria, allowing developers to know what specifications their EHR

technology must meet in order for providers to use it; and

WHEREAS, in order to update the Certification Criteria, improve its

regulatory timeline, and more effectively respond to stakeholder feedback,

ONC issued a Notice of Proposed Rulemaking unveiling the voluntary 2015

Edition of EHR in March of 2014; and

WHEREAS, ONC's EHR Certification Criteria are a vehicle by which ONC can

break the systemic discrimination within the healthcare industry caused by

inaccessible EHR; and

WHEREAS, ONC missed this remarkable opportunity and failed to integrate

accessibility into the Certification Criteria properly, calling only for

increased accessibility for blind patients and not requiring any

accessibility for blind workers who use the technology; and

WHEREAS, the National Federation of the Blind submitted comments in response

to the NPRM urging ONC to amend the Voluntary 2015 Certification Criteria to

include compliance with WCAG 2.0 Level AA; and

WHEREAS, in our filing the Federation noted that compliance must not only

include access for patients but must also meet the needs of blind people who

currently work or who wish to work in the healthcare industry; and

WHEREAS, the National Federation of the Blind supported our comments by

submitting letters on behalf of sixteen blind doctors, nurses, assistants,

therapists, and students who currently work in the healthcare industry or

are pursuing careers in the healthcare industry and who are facing extreme

discrimination as a result of inaccessible EHR technology: Now, therefore,

BE IT RESOLVED by the National Federation of the Blind in Convention

assembled this fifth day of July, 2014, in the city of Orlando, Florida,

that we strongly urge ONC to amend the Voluntary 2015 Certification Criteria

for EHR technology to include accessibility for all users of the technology;

and

BE IT FURTHER RESOLVED that we commend the sixteen blind healthcare

professionals for telling their stories, because the talents and careers of

many individuals are in jeopardy if those currently facing needless

discrimination because of inaccessible EHR technology do not make their

voices heard; and

BE IT FURTHER RESOLVED that we strongly urge the Centers for Medicare and

Medicaid Services, the Department of Health and Human Services, and any

healthcare provider that deploys EHR technology proactively to demand

accessibility from developers, since all of these entities are stakeholders

in this matter and will never fully realize the benefits of EHR technology

unless that technology is accessible to users with disabilities.

 

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