There’s nothing like a crisp New England winter evening, a roaring fire, a cup of cider, and a 242 page Notice of Proposed Rulemaking to fill your Friday night.
I’ve summarized the preamble and all 50 criteria to save you time as you consider the proposals during the 60 day comment period. Note that no vendor needs to implement 2015 criteria and no provider needs to adopt 2015 certified software, hence the term voluntary. In many ways, this document is meant to signal what might be included in the 2017 edition that supports Meaningful Use Stage 3.
Roughly 60% of the 2014 Edition EHR certification criteria are unchanged in the 2015 Edition. The remaining certification criteria proposals for the 2015 Edition fall into four general categories: clarifications, standards updates, revised approaches, and new certification criteria proposals.
As with the Meaningful Use Stage 3 proposals, I’ll pose questions, not to be judgmental but to get us all thinking about the scope, timing, and purpose of the certification program over the next several years.
The preamble highlights several big ideas – elimination of the ‘complete EHR’ designation, separation of content/transport certification criteria, adoption of new standards, more frequent certification rule making, and the need for 2017 edition proposal feedback.
Complete EHR was a very confusing concept to me that led many to buy single vendor systems as the “safest” option instead of assembling modules. I applaud the idea of eliminating terms like Complete EHR and Optional Certification criteria. Each certification criterion should stand alone and during attestation you should “fill your shopping cart” with only the certified modules you need.
Separating the content and transport certification criteria is a good thing. The 2014 Edition which linked the two concepts proved to be very problematic in Massachusetts where the state HIE performs all of the Direct and XDR functions we need, so no EHR requires transport capabilities. Yet because EHRs had to be certified to do both content and transport interoperability, extra work and expense was incurred.
The logic behind more frequent certification rules is that it enables “bug fixes” and more rapid adoption of standards. However, we should ask the question – even with a voluntary program, just how fast can we develop software, install upgrades, revise workflow, educate clinicians, and support new software versions? My experience is that changes of this nature take 3 years from regulation to attestation, at a minimum.
Here’s my advice while reading the 50 certification criteria:
Focus on the fixes. There were many challenging issues in the 2014 Edition. The 2015 Edition fixes several of them. Even if something looks more complex (like separating content and transport criteria), it is simpler, and provides more market flexibility.
Identify the burden reduction. Vendors of “non-MU Eligible” software such as long term post acute care no longer need to develop “MU-required” functionality such as measure calculation to get certified. …read more
