The Electronic Health Record Association (EHRA) has delivered its comments on the Notice of Proposed Rulemaking (NPRM) on the Voluntary 2015 Edition EHR and the proposed timing of the rule has the EHR vendors concerned.
In a letter to the head of the Office of the National Coordinator for Health Information Technology (ONC), the EHRA identifies two areas of the proposed rule: the frequency of certification and the risks associated with improvements to clinical quality measures (CQMs).
As members of the ONC explained at HIMSS14 in February, the federal agency is aiming to untether the EHR certification process from the rulemaking for the EHR Incentive Programs. The 2015 Edition is the first set of certification rules not tied to a particular stage of meaningful use, as was the case with the 2011 and 2014 Editions.
According to the ONC, the new approach will enable certification to keep pace with innovation and allow for more timely iteration. Apparently, that doesn’t sit well with the EHRA:
While framed in the NPRM preamble as being responsive to and addressing EHR developers’ challenges created by uncertain regulatory timelines, this proposed rule focused on a 2015 certification edition and proposing a more frequent certification cadence does not in fact address this issue. In particular, the proposed rule specifically does not respond to our repeated requests for final rules and all supporting materials and tools at least eighteen (18) months in advance of when providers and others expect certified products to be available.
Members of the association are asking the ONC to apply a new label to the 2015 Edition, redubbing it’s the 2016 Edition in order to ” to provide some semblance of reality in terms of expectations by other federal agencies and EHR users as to when some of the final proposed functionality might be implemented.” The EHRA is also reminding the ONC of competing sources of requirements for product functionality — that is, their own customer base.
The other key concern of the EHRA center of improvements to the electronic CQM and clinical decision support (CDS) process, something its members are actually supportive of:
However, we are concerned that the compressed timeline for this initiative does not allow adequate time to ensure that the critical improvements already underway to the CQM development, testing, and implementation process continue to advance, and are not compromised by rapidly changing standards and requirements that are only just evolving.
The association is calling on the ONC to remove the CDS/CQM proposed standards from the 2017 Edition that is intended to coincide with Stage 3 Meaningful Use. ” We urge ONC and CMS to consider a more incremental approach to the eventual implementation and adoption of these standards, ensuring that each one has been fully tested and piloted prior to requiring adoption by all EHRs,” the letter states.
Given the decision earlier this week that athenahealth would be leaving the association, the feedback from the EHRA on the 2015 and 2017 Editions supports the cloud-based health IT developer’s that its support of “aggressive timelines and high standards” were indeed not shared by others in the group.
