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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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.
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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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