The big news that had to be covered today was the announcement by the EHR Association about the EHR Developer Code of Conduct. The core topics of the EHR Developer Code of Conduct are great:
- General business practices
- Patient safety
- Interoperability and data portability
- Clinical and billing documentation
- Privacy and security
- Patient engagement
Certainly there are other areas that I would have loved to see included, like EHR usability, but if we could address each of the areas listed above we’d have a big improvement over where we are today. Be sure to also check out the EHR Developer Code of Conduct and FAQs document and the EHR Developer Code of Conduct Implementation Guide for the full details on the EHR Code of Conduct.
The problem I have with this EHR Code of Conduct is that it has no teeth. There’s no enforcement mechanism or reporting mechanism to show how an EHR vendor has chosen to implement the code of conduct. They won’t even commit to having a list of EHR vendors that have adopted it. Trust me when I say that for every element of the EHR Code of Conduct, there’s A LOT of room for interpretation.
Where there’s room for interpretation, there’s room for abuse.
Obviously, when you bring together 40 EHR vendors it’s a real challenge to create something that has no interpretation. However, it seems they could have created a way to display how an EHR has chosen to meet the EHR code of conduct guidelines.
For example, the guideline says, “We will work with our customers to facilitate the export of patient data if a customer chooses to move from one EHR to another.” Then, it even sets a minimum export of a CCD/CCDA document. We could discuss how that type of document is nearly enough to switch EHR software, but even if it was enough, there’s a lot of ways you could implement this guideline. An EHR vendor could let the customer download a CCD for each patient individually and leave it to the customer to download all 5000 individual CCDs for their patients. That meets the guideline, but would be very different than an EHR vendor that gave you a one click download of CCDs for all your patients.
This qualitative data about how an EHR vendor has implemented the code of conduct should be easily available to doctors to compare across vendors. Otherwise, it has much less meaning and a lot of doctors will get bamboozled by the impression “commitment to the EHR Code of Conduct” implies. It’s similar (and even worse) than the pass/fail EHR certification. Not all certified EHR are created equal and not all EHR Code of Conduct adopters will be equal either. Why not be transparent about how they meet the code?
In the webinar they suggested that “the industry itself will kind of make it transparent who has adopted the code and who hasn’t adopted the …read more