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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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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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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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…)

EHRA Responds to ONC’s Interoperability Roadmap

After many conference calls, and lots of “on the job training” using Google Docs to manage the edits of many contributors, we were pleased to submit our response to ONC’s Interoperability Roadmap. . . just in time to start working on the interoperability aspects of the proposed rule for Stage 3 of the EHR Incentive Program . . .and to get ready for HIMSS15!

Overall, we’re positive about the framework the draft Roadmap is starting to put in place, its identified principles, and the pragmatic review of well-established and emerging interoperability standards and technologies. We did express some concern that ONC seems to view the many active, and increasingly successful, interoperability initiatives as a problem to be solved rather than work to inform go-forward strategies with valuable experiences to be built upon. In doing so, we provided some positive suggestions on how to approach interoperability governance in ways that rely on and leverage private sector efforts in the context of an effective public/private partnership.

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