The HIMSS Electronic Health Association (EHRA) has weighed in against ONC's proposed 2015 edition of EHR certification criteria, calling it "costly" and "not desirable."
In its comment letter to National Coordinator for Health IT Karen DeSalvo dated April 22, the EHRA pointed out that while the proposed rule is touted as being responsive to EHR developers' challenges about dealing with uncertain regulatory timelines, this proposed rule is not responsive to developers' requests that they be provided with at least 18 months to develop certified products. Moreover, this proposed edition of certification criteria would allow less than a year to come up to speed.
"[W]e believe that the stated intention to move to more frequent certification, and this NPRM in particular [in the parts outlining 2015 certification requirements], moves in the opposite direction from our request for adequate time to deliver high quality software, and for our customers to prepare to use it in a meaningful and safe way. It also runs counter to our strong belief that post-2014 certification should be highly focused on interoperability and build on Stage 2 criteria rather than introducing new functional criteria," the letter stated.
EHRA also expressed concern that the 2015 edition introduces complex new criteria with "minimal" evidence of provider demand that are not in the Stage 3 proposed requirements approved by the Health IT Policy Committee, such as burdensome drug/drug and drug/allergy interaction tracking. At the very least, the EHRA said the 2015 edition should be re-labeled the "2016" edition.
Additionally, the EHRA worried that the compressed timeline to align standards for clinical decision support and clinical quality measures in the rule would not allow enough time to ensure that improvements to them would continue to advance and not be compromised.
The proposed new certification criteria is the first edition of certification criteria not tied to actual Meaningful Use Regulations, and will be voluntary. The final rule is expected summer 2014. Notices of Proposed Rulemaking for Stage 3 and the 2017 edition of the certification criteria is expected by fall 2014.
To learn more:
- read the comment letter (.pdf)