The USCDI Curation Process: Why Stratify?

By John Travis and members of the EHRA Information Blocking Task Force 

In our last blog on the United States Core Data for Interoperability (USCDI), the focus was on USCDI as the policy ground for advancing federal interests for promoting high impact needs for health data, and USCDI’s import as a certification specification impacting developers of Certified Health Information Technology (CHIT). In this blog, we focus on how the evolution and curation of USCDI impacts the efforts of health IT developers and implementers to “stay current.” 

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The Balance Challenge for Policy in Progressing the U.S. Core Data for Interoperability (USCDI)

By John Travis and members of the EHRA Information Blocking Task Force

 

With publication of the 21st Century Cures Act: Interoperability, Information Blocking , and ONC’s Certified Health IT program final rule (Cures Act Final Rule), the Office of the National Coordinator for Health IT (ONC) worked to implement important provisions of the 21st Century Cures Act (Cures Act) for nationwide interoperability. The initial proposal from ONC addressing the Trusted Exchange Framework and Cooperative Agreement (TEFCA), which was also required by the Cures Act, created a central role for the U.S. Core Data for Interoperability (USCDI) in federal health IT policy, and it is important to consider what that role will be in the national policy framework. Will the USCDI push the industry beyond where it would go on its own by being progressive in its version expansion? Will it affirm and codify an extension of the current state, adhering to a principle of expansion based on supporting pre-requisites of already established interoperability standards? Or something in between?

In recent deliberations of the USCDI Task Force of the Health Information Technology Advisory Committee (HITAC), the Federal Advisory Committee established under the Cures Act, this tension point has come to light. The members of the task force seem to have two perspectives on the matter. 

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An EHR Perspective on the Consumer-Focused API/App Landscape

By Hans Buitendijk
EHRA Executive Committee member
Chair, Interoperability & Standards Workgroup

kevin-grieve-712217-unsplashONC’s 2015 Certification Edition for EHRs began supporting consumer access to their health data beyond patient portals. Open APIs were required to enable consumer Apps to access data from the Common Clinical Data Set. Because at the time there were no standards sufficiently mature to establish as a base, the requirement allowed for access by any means as long as the technical specifications, including terms and conditions, were made publicly available to enable App developers to write their Apps on top of these APIs.

A lot has happened since then.
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IPPS: Ambiguous Measures Won’t Reduce Burden

By Sasha TerMaat
Co-Chair, EHRA Executive Committee

man holding three white medication pills

The final 2019 IPPS rule included changes to the Promoting Interoperability/ Meaningful Use program beginning January 1, 2019. Disappointingly, with only six weeks between the close of the public comment period for the proposed rule in late June and the publication of the final rule in early August, CMS’ rushed process and failure to fully consider stakeholder comments (including EHRA’s) led to a rule filled with measures that will be unworkable, inefficient, and onerous.

In a previous blog we delved into PDMP query as just one of the measures where EHR developers anticipate challenges. In that case it’s due to differing levels of PDMP integration with CEHRT and inconsistent references within the rule about whether the query needs to be made via CEHRT, along with other areas in which the measure is ambiguous.  

In this blog post, let’s look at the reasons we’re concerned about a different measure, this one related to opioid treatment agreements.

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Don’t Create a Certification Ceiling

By Sasha TerMaat


Certification blog quoteAt the end of November 2017, JAMIA published the article,
“Are all certified EHRs created equal? Assessing the relationship between EHR vendor and hospital meaningful use performance.” The authors, A Jay Holmgren, Julia Adler-Milstein, and Jeffrey McCullough, performed a statistical analysis of publicly available data sets on Meaningful Use EHR Incentive Program performance, stratifying based on the developer of the EHR product used by the Meaningful Use participant.

It’s wonderful to see the data sets published by CMS and ONC used for insightful research. I know from personal experience doing data analysis of CMS and ONC published data sets that a lot of effort goes into data normalization, and the authors took a thoughtful and careful approach.

However, I was surprised by the authors’ conclusions and policy recommendations at the close of the article. Having found EHR developer-correlated variability in performance on certain activities measured in the Meaningful Use incentive program, the authors state that is undesirable, and write recommendations to standardize. The authors say, “Our results suggest that policy-makers should pursue modifications to the EHR certification process to decrease such variation across EHR vendors and improve EHR systems.” (more…)

New Certification Criteria for APMs–Is This the Right Approach?

CMS and ONC are considering tying the new Alternative Payment Models (APM) being designed per the MACRA legislation to prescriptive criteria for “use” of certified EHR technology, and considering development of new certification criteria specifically created for APMs.  In doing so, do they risk going beyond congressional intent for the APM program and stifling innovation by imposing requirements on health IT beyond what is sought in the market, perhaps pursuing a strategy that may not be the best way to accomplish their end-goals – the rapid shift to value-based reimbursement and more integrated care?

Read “Health IT, Value-Based Payment, and Innovation: Let’s Get it Right” by Mark Segal, PhD (EHRA Chair Emeritus and Vice President of Government and Industry Affairs for GE Healthcare IT) on the GE blog page.

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