We acknowledge a need for federal governmental leadership that accelerates the potential of PHRs to empower the consumer. However, certification should not be a governmental focus at this time. The risks outweigh any potential benefits. If this recommendation goes forward, it will create momentum for certification is likely to ignore a broad range of critical policies and, as well, stifle innovation by prematurely locking in current approaches to PHRs and deter new entrant in a field that is newly developing. A premature process for certification–even if it begins as voluntary and attempts to limit itself to privacy, security, and interoperability–risks undermining opportunities to empower consumers and improve the quality of care.
