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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MACRA: Then and Now

By David Heller

MACRA

How much do you know about Congress’ effort to “rein in” expenses associated with healthcare’s fee-for-service system with the passage of MACRA?

Incentivizing value-based care was the goal of the Medicare and CHIP Reauthorization Act of 2015, aka MACRA, writes David Heller of the EHRA Public Policy Committee and Corporate Counsel for Regulatory Affairs at Greenway in an article tracing MACRA’s policy roots and offering recommendations for its future in the American University Health Law and Policy Brief.

In the article, “MACRA: Emerging from the Thicket,” Heller explains some of the reporting complexities that the Congressional authors of MACRA were trying to address.

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Standardizing Data Collection to Support Clinicians in the Opioid Fight

By David Bucciferro and Katelyn Fontaine
EHRA Opioid Crisis Task Force 

Dataset Infographic

Click here to open image in new window.

Volunteers on EHRA’s Opioid Crisis Task Force have made great strides in the past year in our efforts to identify the policy changes and adoption patterns needed to maximize the capacities of health IT to combat the opioid crisis.

From the start, our focus has been, What do providers need from technology to support their efforts in the opioid crisis?

When we began our work in early 2018, we were surprised to find that there was no comprehensive source for the state-specific policies and standards surrounding prescription drug monitoring programs (PDMPs) and electronic prescribing of controlled substances (EPCS). So, we set out to create our own.

State by state, we collected data, including timeframes for reporting controlled substance prescriptions to PDMPs, what data is collected, which professionals are able to access PDMP information, if and when information can be shared across states, and any limits on retaining PDMP data within an EHR.

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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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Why HHS Needs a Privacy Leader and a Cybersecurity Leader

By Nam Nguyen and Sayee Balaji Chandrasekaran, Chair and Vice Chair, EHRA Privacy & Security Workgroup

_Security and Privacy are not the same. A Security leader_s primary concern is protecting and securing data. A Privacy leader_s primary concern is who can access certain data and whaCyber-threats are all over the news, including attempts to hack elections, steal corporate trade secrets, and hold medical records for ransom. Phishing is rampant, and is the way most hackers ultimately get into secure systems. The U.S. government has, of course, taken notice, and is taking action on several fronts.

One of those fronts is healthcare, with the release by HHS of the Health Care Industry Cybersecurity Task Force’s “Report on Improving Cybersecurity in the Health Care Industry,” which was delivered to Congress in June 2017.  The task force wrote, “Our nation must find a way to prevent our patients from being forced to choose between connectivity and security.”

EHRA welcomes this report, which we view as a path forward for increasing security in the healthcare sector.  The report directly aligns with two of EHRA’s privacy and security positions: (more…)

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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