Final IPPS Rule Ignores EHR Developer Concerns–Includes Impossible Measures, Will Lead to Increased Clinician Burden

By Sasha TerMaat
EHRA Vice Chair

IPPS blogOn August 2, 2018, CMS published the 2600-page pre-publication version of the 2019 IPPS Final Rule. EHRA members have begun digging into the Promoting Interoperability/Meaningful Use program, hoping to see changes based on their public comments on the proposed rule released in May. While we’re glad to see the requirement for 2015 CEHRT in 2019 confirmed, overall we’re disappointed that CMS failed to respond to many of EHRA’s comments as well as other stakeholder feedback.

In releasing the final rule less than six weeks after the public comment period closed (during which it received 1,058 comments), CMS appears to have rushed what should have been a thoughtful process. Several measures will be infeasible to program. Other measures will result in additional burden on clinicians, solely for the purpose of measurement rather than improved patient care. (more…)

HIMSS18: Listening, Learning, Leading

IMG_6591EHRA member companies were out in force at HIMSS18 in Las Vegas, and not just in booths on the exhibit floor.

In a small conference room on the 4th floor of the Sands Convention Center, EHRA volunteer executives were meeting with stakeholder groups to discuss how EHRs can be optimized to improve usability, interoperability, and patient safety. We listened, we asked questions, and we shared our perspectives on the challenges and what the next steps could be.

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Draft TEFCA Needs A Lot More Work

TEFCASince the release of the Draft Trusted Exchange Framework and Common Agreement (TEFCA) on January 5th, EHRA volunteers from the Standards and Interoperability, Privacy and Security, and Public Policy Leadership Workgroups have been reviewing and discussing the document. Together, they drafted EHRA’s comments, which were submitted this week to the Office of the National Coordinator for Health IT (ONC).

As EHR developers, we support the goal to provide nationwide interoperability using networks as important building blocks, and believe TEFCA has the potential to dramatically improve interoperability.

However, the draft TEFCA overreaches, neglects important details, and doesn’t consider the practicality or potential unintended consequences of the policy. We strongly recommend that ONC review stakeholder feedback and publish a revised proposed draft for another round of feedback, before finalizing the policy.

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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…)

FDA Health IT Guidance Is A Good Start, But More Clarity Is Needed

By Shari Medina, MD

This month, the FDA issued long-awaited guidelines EHR tablet graphicon the agency’s implementation of the 21st Century Cures Act in regards to Clinical Decision Support and the FDA’s intent to exercise enforcement discretion for many types of patient-facing software, mobile applications, and software which have not obtained ONC certification.
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Improving EHR Usability by Reducing Regulatory Burdens

it is our experience that clinicians_ frustrations with EHRs are often less about the technology, and more about using it not simply for patient care but to fulfill regulation-driven dIn a speech last month, CMS Administrator Seema Verma expressed her desire for CMS “to focus on patients first.” To do this, she said, “one of our top priorities is to ease regulatory burden that is destroying the doctor-patient relationship. We want doctors to be able to deliver the best quality care to their patients.”

We applaud Administrator Verma for leading this effort to reduce regulatory burdens on healthcare providers. As regulatory requirements for data collection from clinicians directly through the EHR have increased, it has become increasingly more challenging to maintain focus on the data essential to direct patient care. (more…)