Attachment L - Public Comment American Academy of Pediatrics

September 29, 2009
141 Northwest Point Blvd
Elk Grove Village, IL 60007-1098
Phone: 847/434-4000
Fax: 847/434-8000
E-mail: kidsdocs@aap.org
www.aap.org

Agency for Healthcare Research and Quality
ATTN: OMB Desk Officer
540 Gaither Rd
Rockville, MD 20850
OIRA_submission@omb.eop.gov
To Whom It May Concern:

Executive Committee
President
David T. Tayloe, Jr, MD, FAAP
President-Elect
Judith S. Palfrey, MD, FAAP
Immediate Past President
Renée R. Jenkins, MD, FAAP
Executive Director/CEO
Errol R. Alden, MD, FAAP

Board of Directors
District I
Edward N. Bailey, MD, FAAP
Salem, MA
District II
Henry A. Schaeffer, MD, FAAP
Brooklyn, NY
District III
Sandra Gibson Hassink, MD, FAAP
Wilmington, DE
District IV
Francis E. Rushton, Jr, MD, FAAP
Beaufort, SC
District V
Marilyn J. Bull MD, FAAP
Indianapolis, IN
District VI
Michael V. Severson, MD, FAAP
Brainerd, MN
District VII
Kenneth E. Matthews, MD, FAAP
College Station, TX
District VIII
Mary P. Brown, MD, FAAP
Bend, OR
District IX
Myles B. Abbott, MD, FAAP
Berkeley, CA
District X
John S. Curran, MD, FAAP
Tampa, FL

Thank you for the opportunity to comment on the Health IT Community Tracking Study 2009. The
American Academy of Pediatrics (AAP) is an organization of 60,000 pediatricians, pediatric
medical subspecialists, and pediatric surgical specialists committed to the attainment of optimal
physical, mental, and social health and well-being for all infants, children, adolescents, and young
adults.
The AAP encourages the use of electronic prescribing (e-prescribing) by its members. In 2007, we
published a policy statement an accompanying technical report titled, “Electronic Prescribing
Systems in Pediatrics: The Rationale and Functionality Requirements.” Both documents are
attached for your consideration. The AAP recognizes the potential for e-prescribing to reduce
medical errors and enhance patient care. However, many e-prescribing systems today do not
include basic functionality required when prescribing medications for children, eg, the ability to
calculate medication dosage based on age, weight, or body surface area. It is extremely important,
when integrating new technology into the patient care environment, that consideration is given to
how the new processes will impact patient outcomes.
In addition, pediatricians frequently report that their local pharmacies do not recognize when an
electronic prescription has been transmitted. Families may arrive at the pharmacy only to be told
that their doctor never sent the prescription. This situation can lead to inefficiency and negative
publicity for the pediatrician’s practice, and may cause the pediatrician to revert to paper
prescriptions.
We recommend that researchers conducting the pilot test include pediatric practices among the
study cohort. If this is not possible, we request that AHRQ consider a separate study of ambulatory
pediatric primary care, medical subspecialty, and surgical specialty practices, since pediatric
practices may have specific needs and concerns related to e-prescribing. In addition, we
recommend that the study include both solo/small group practices and large group practices in
order to effectively compare implementation strategies in these very different environments.
The AAP applauds your efforts to understand the pros and cons of e-prescribing for healthcare
providers in all care settings. We stand ready to provide assistance should the Agency desire
additional input or participation. If you have any questions, please contact Jennifer Mansour
(jmansour@aap.org) or Beki Marshall (bmarshall@aap.org) in our Division of Pediatric Practice at
800/433-9016, ext 4089.
Sincerely,

David T. Tayloe, Jr, MD, FAAP
President
DTT/bm
Enclosures