May 17, 2011 The Honorable Mark Leno California State Senate State Capitol, Room 5100 Sacramento, CA 95814 Subject: SB 850 (Leno) - OPPOSE Unless Amended Dear Senator Leno: The California Hospital Association (CHA), representing nearly 400 hospitals and health systems, has taken an oppose unless amended position on SB 850. Many of California's hospitals are actively engaged in implementing electronic health record (EHR) systems in support of national efforts to that will result in available and accurate data for quality and safe patient care. While the use of electronic records provides new challenges to documentation CHA believes the frequency of the problem addressed in this bill does not make the cost justified at this time when hospitals are focused on achieving sustainable health information exchange and in demonstrating federally defined meaningful use of clinical data. CHA respectfully asks that you delete the following language: "The record of the change or deletion shall be made part of the patient's medical information, and shall be accessible upon request of a patient or his or her representative to review the medical information." Electronic health record systems do not currently support this level of reporting within the patient record. While the record of detail of change or deletion in the record is maintained in administrative auditing of data, it is not currently reported in the clinically focused record documentation. CHA believes the auditing metadata should remain separate from the clinical data until new national security standards are developed. The costs to revise vendor systems to meet the proposed requirement will result in millions of dollars of programming changes to systems already installed in California's hospitals and will result in major delays to hospital EHR system projects awaiting implementation. CHA appreciates your consideration of this amendment and looks forward to continuing to work with you in achieving health care access and reform in California. Sincerely, Connie Delgado Deputy Chief Legislative Advocate CD:dlv