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…)

To Improve Patient Access to Data, Providers and Developers Need Clarity on Regulatory Requirements, Not a Focus on Compliance and Penalties

By the EHR Association Executive Committee

Recently, a blog post appeared on the Health Affairs website* painting a gloomy picture of patient access to their electronic health information and suggesting a new theory on how HIPAA can be used to accelerate expansion of interoperability.HA blog quote

Disappointingly, this timely blog post makes inflammatory and inaccurate assertions about EHR vendors, regulatory requirements, and progress made toward interoperable health records.  It also seemingly advocates for a “gotcha” system of penalizing potential missteps by providers and developers, which is the wrong approach to encouraging information sharing.

EHR developers provide tools to help our customers care for patients and increase these patients’ access to their health information. The assertion that individuals “struggle to get their information out of EHRs in an electronic format” overstates the situation and does not reflect progress made.  Although the extent of exchange is not yet where the healthcare industry collectively would like it to be, interoperability is growing quickly between providers, as well as between providers and patients.

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Interoperability Framework Should Build Upon Existing Technology

This week, EHRA submitted comments to ONC regarding the 21st Century Cures Act (Cures) Trusted Exchange Framework and Common Agreement implementation.

You can read EHRA’s recommendations here.  Our comments focus primarily on: (more…)

EHRA Reiterates Key Recommendations for Program Alignment and Practicality in Comments on HOPPS

As we generally do with proposed regulations that impact EHR developers and their customers, the Electronic Health Record Association (EHRA) carefully reviewed and collectively commented on CMS’s proposed rule on the Hospital Outpatient Prospective Payment Systems (HOPPS) and EHR Incentive Program on September 1. Our comments, submitted on September 1 and available here, are based on the collective experiences of more than 30 EHRA member companies who service the vast majority of hospitals and ambulatory care providers using EHRs across the United States.

We put forth two key positions. The first centers around advocating for program alignment across Medicare and Medicaid requirements, as well as the EHR incentive programs with the Merit-Based Incentive Payment System (MIPS). The second states strongly that changes to the EHR incentive program at this late date relative to the current or next reporting period lead to costly and negative repercussions. We strongly recommend that CMS make every effort to incorporate the comments received up to and including this comment cycle in future rulemaking, in order to set appropriate and achievable requirements and deadlines to reduce the need for mid-year revisions.

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