Yesterday, New York’s OMRDD issues a policy statement on Electronic Signatures and Records.  You can read it here.  The statement references an older document from OMIG which you can read here.

Both of these documents are available in our expanding New York Reference Documents section.

These documents confirm our position that electronic signatures are valid except where otherwise indicated in regulation.

Also, the statement says:

The electronic medical record must have a control feature which date stamps each entry into the record that cannot be turned off or over-written.

So, if you have a system which allows one of your employees to make undocumented changes, or, your provider is able or willing to do so then you do not have an electronic record in the eyes of New York State.

This is, to me, a very clear vindication of Therap’s model and system.

If you have any questions, please do not hesitate to contact me.  We will of course be discussing this and all its implications in Fishkill in February

:: Justin ::