Will voluntary 2015 criteria help MU?
At the same time that a huge coalition of health organization asks for more flexibility in the current phase of the EHR incentive program, federal health IT regulators are proposing a new, voluntary certification for 2015 that they think could solve a number of current quagmires.
The Office of the National Coordinator wants to create an EHR certification system for 2015 that would be guided by a more “effective response to stakeholder feedback,” incorporate “bug fixes” to make 2014 certification rules “clearer and easier to implement,” and “reference newer standards and implementation specifications.”
[See also: ONC proposes 2015 certification criteria]
The end goal is "promoting innovation and enhancing interoperability,"ONC regulators wrote in what is first certification proposal separate from the Centers for Medicare & Medicaid Services’ regulations. The 2015 certification system would be voluntary for both providers and EHR developers, offering them both the ability to move ahead “on their own terms and at their own pace,” as national coordinator Karen DeSalvo, MD, said in a media release.
Although ONC regulators "do not expect a majority of EHR technology developers to seek testing and certification to the 2015 Edition,"if the new certification meets its objectives, eligible providers would have more choices with “updated capabilities, standards, and implementation guides.”
In one major change, they’re proposing to separate EHR "content" and "transport" capabilities, as well as "view, download, transmit to 3rd party" criteria, to expand health information exchange services in part by making it easier for patients to choose where they want to send their information.
"(W)e have determined that it would best support industry interoperability approaches and provider choices for electronic exchange services if we permitted ‘data content’ capabilities to be tested and certified separately from ‘data transmission’ capabilities," ONC regulators wrote.
[See also: ONC: Stay the course on Stage 2]
Among other changes are certain "bug fixes" aimed at streamlining what in past certifications some have considered overly-prescriptive policies, such as for computerized provider order entry.
"(W)e can understand why our approach to CPOE certification can be interpreted by some providers as inconsistent with the flexibility" intended in the program, ONC regulators wrote.
In the meaningful use stage 2 CPOE objective, eligible physicians have three measures to attest for based on three types of orders, with three related exclusions. “An EP who could potentially meet an exclusion for one or two of the measures would still need to possess EHR technology certified to the 2014 Edition CPOE certification criterion,” with capabilities for all three orders. Likewise in the first stage of meaningful use, EP CPOE objectives don’t include lab and radiology orders, “which means EPs attempting this objective also do not necessarily require these additional certified CPOE capabilities.”
To address those problems, the ONC is proposing to split CPOE certification into three separate criteria each focused on one of the three order types, so that developers can better tailor their products based on their customers needs.
"If an EP expects to meet the MU exclusion for one or two of the MU measures (i.e., writing fewer than 100 of each order type during an EHR reporting period), they could choose to adopt EHR technology certified only to the 2015 Edition CPOE certification," ONC regulators wrote.
That type of flexibility carries the risk of making attestation more complicated, however. EPs might expect to qualify for one or more of the exclusions but not ultimately satisfy them based on the number of orders written, regulators cautioned.
"EPs who choose to possess EHR technology that is not certified for each of the three types of orders may risk not having EHR technology that meets the CEHRT definition if they ultimately fail to meet one or more MU exclusions."
With digital order and communication of lab reports growing more common, the ONC is also proposing certification changes to lab-related exchanges as governed by the Clinical Laboratory Improvements Act. In ambulatory settings, they’re proposing adopting standards based on the HL7 Version 2.5.1 Implementation Guide: S&I Framework Laboratory Orders from EHR, Release 1–US Realm.
In other areas of standardization, the ONC is seeking more advice – for the 2017 certification.
In the 2014 certification, regulators did not require EHRs to record vital signs in any of the LOINC, SNOMED or UCUM standards, deeming it “too complex and burdensome for technology developers to map workflows, templates, and forms used to capture vital signs to standardized vocabularies” and potentially leading to workflows clinicians wouldn’t find helpful.
Now, though, they’ve "continued to receive stakeholder feedback that we should consider adopting standardized vocabularies for recording vital signs," as well as feedback suggesting the contrary. More input from more stakeholders could help them decide which way to go, they said.
For 2017, the ONC is also seeking comment on another rather significant EHR technology: drug-drug and drug-allergy contraindications, or DDI/DAI. While EHRs are currently certified to do those types of checks, the ONC is wondering if they should try to certify EHRs to track clinicians responses to DDI/DAI checks, specifically, "if and when the health professional viewed, accepted, declined, ignored, overrode, or otherwise commented on the product of a DDI/DAI check."
Those and other proposals in the 242 page document being published in the Federal Register February 28 are open to comment through April 28.
The idea comes just as 48 healthcare stakeholder associations, including the AMA, the AHA, AHIMA, CHIME and MGMA, are calling on the Department of Health and Human Services to extend timelines through 2015 for providers to implement 2014 certified EHRs and “add flexibility” to “permit as many providers as possible to achieve success in the program.”
In a letter to HHS Secretary Kathleen Sebelius released at HIMSS14, the associations argued that the "pace and scope of change have outstripped the ability of vendors to support providers," with at least some hospitals and physicians facing a chaotic transition.
"We are concerned this dynamic will cause providers to either abandon the possibility of meeting meaningful use criteria in 2014 or be forced to implement a system much more rapidly than would otherwise be the case," the organizations wrote. "The first choice limits the success of the program to achieve widespread adoption of EHR, while the second is highly disruptive to healthcare operations and could jeopardize patient safety. As you know, our members’ number one priority must be to provide safe and high quality care to patients."