A Focus on Standards 

Screen Shot 2019-07-04 at 6.19.08 PMOn June 3, EHRA submitted feedback to ONC on its proposed rule, the  21st Century Cures Act: Interoperability, Information Blocking, and the ONC Health IT Certification Program. In this feedback, EHRA members drew on both their expertise as software developers and as contributors to standards work across the health IT industry. 

One theme of EHRA and other stakeholders’ feedback is that a focus on standards is critical. A particular standard proposed recently by ONC is the United States Core Data for Interoperability, or USCDI. USCDI “is a standardized set of health data classes and constituent data elements for nationwide, interoperable health information exchange” and includes important health data classes. 

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EHR Developers are Aligned with Goals of Cures NPRM, Hope ONC will Remove Ambiguity and Reassess Timeline

Screen Shot 2019-05-26 at 9.15.33 PMWe had been waiting for the Office of the National Coordinator for Health IT to release the proposed rule fulfilling its Cures Act obligation for quite a while. Encompassing important issues like expanded interoperability, defining what is and isn’t information blocking, as well as proposing updated certification requirements, this is an important rule to get right.

Since the release, there have been lots of discussions—public and private, online and off—about intended and potentially unintended impacts of the language in the proposal. With so much to consider and analyze, we appreciate that the request from EHRA and other groups to give us a full three months to draft our comments on the rule was approved.

The tremendously broad reach of the proposed rule goes far beyond Congressional intent.

The EHR Association’s comments are now going through final rounds of review by our executive committee (and the seven workgroups and task forces that contributed their expertise). We worked throughout the drafting of the 21st Century Cures Act with Congress and are supportive of its goal to remove obstacles to information exchange, but we have found that the tremendously broad reach of the proposed rule goes far beyond Congressional intent. In particular, we have significant concerns regarding timelines, ambiguous language, disincentives for innovation, and definitions related to information blocking.

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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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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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    Elinore Boeke
    Communications and Media
    elinore @ kecommunications.net