This past Monday, May 7, 2012 I submitted comments for Stage 2 Meaningful Use Proposed Rule from CMS and the Certification and Standards Criteria for EHRs Proposed Rule from ONC.  After three years, over 30 public comments and more patience than I had imagined, I took the recommendation to create a “Business Case” for nutrition inclusion in EHRs.  I love to write, am intrigued to learn more each day and thought I had a good idea of the state of things.  (And the reason we even care to comment is that getting nutrition included in EHR certification under the regulations of HITECH will give us a better stab at improving health through nutrition.)

What unfolded was a new look of how nutrition can impact health care.  I started with the 2010 preliminary report on the “Top 15 Causes of Death.”  I had been using the “nutrition impacts the top 7 out of 10 causes of death in America.”  After the research, my comments included that nutrition impacts potentially 11 out of the top 15 Causes of death in America.  Granted that’s only a 3 percent increase from the previous phrase,  what replaced “homicides” as 15^th left me concerned.  The new “15^th” spot was disturbing: “Pnemonitis due to solids and liquids.”  Having read of member reports of miscommunications in diet orders and tube feedings for a few months, it was, on the one hand—further validation nutrition has to be included as key clinical data in health IT—and on the other hand—a huge disappointment that this was an issue, that likely was related to nutrition care.  Following is my table and the implication of $1.18 Billion we spend on these conditions every year.  We have a lot of work to do.