November 10, 2011
Statement Type Regulatory Comment
AMIA acknowledged NIST’s efforts to highlight the importance of usability testing for electronic health records (EHRs) through its issuance of the proposed guidance. AMIA expressed concerns about several aspects of the draft guidance including the following: a limited and narrow identification of EHR users; the need to consider more comprehensive usability factors; inclusion of documentation about user-centered design; and the creation of a fourth phase of user testing- in real world situations. AMIA also suggested that NIST enhance its categorization of users to reflect the multidisciplinary and team approach to care delivery and proposed that NIST include patients and families as part of the health care team. Finally AMIA offered its assistance to NIST as they continue to address these important topics, noting the convening of an AMIA Task Force on Usability.