Scoring is a Primary Concern with CORE’s proposed ASN eCQM

By Toni Wilken (Meditech), Vice Chair, Quality Measures Workgroup

Creation of the proposed Addressing Social Needs (ASN) electronic quality measure (eCQM) supports the important goal of addressing an unmet need in patient care by helping to improve screening and coordination with local and community-based resources. However, the EHR Association has identified several issues with the measure as proposed by its developer, Yale New Haven Health Services Corporation–Center for Outcomes Research and Evaluation (CORE), which we shared recently in our response to CORE’s call for comments.

ASN eCQM

Briefly, the Centers for Medicare & Medicaid Services (CMS) engaged CORE to develop a re-designed measure to evaluate how well hospitals were screening for and following up on the social needs of their patients. The result was the ASN eCQM, which is designed to measure screening of patients for social needs within four domains – food insecurity, housing insecurity, utility insecurity, and transportation insecurity – as well as if an intervention activity is performed. 

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SDOH and Health Equity Task Force

By Janet Campbell (Epic), Chair, SDOH & Health Equity Task Force

Recognizing an important opportunity for the EHR Association to be a proactive leader in the burgeoning and increasingly critical field of social determinants of health (SDOH) and health equity, the Association has kicked off its recently established SDOH & Health Equity Task Force. 

EHRs have revolutionized the healthcare industry and even how care is delivered. But the practice of addressing social risks and delivering care equitably varies widely across organizations. Thus the role of the EHR  – and therefore the role of health IT developers – remains largely undefined. The potential for EHRs to advance SDOH and health equity is significant, including the proactive collection of demographic and determinant data, segmenting quality reports to uncover disparities, and facilitating prompt closed-loop community-based organization (CBO) referrals. 

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HTI-1 Patient Requested Restrictions Risks Negative Unintended Consequences

By David Bucciferro, Chair, EHR Association

In previous installments of this five-part blog series on the EHR Association’s concerns with ONC’s Health Data, Technology, and Interoperability: Certification Program Updates, Algorithm Transparency, and Information Sharing Proposed Rule (HTI-1), we discussed our overarching concerns, as well as concerns specific to the Insights Condition program, transition to USCDI v3, and Decision Support Interventions (DSI) and Predictive Models. In this blog, we take a closer look at our issues with the proposed Patient Requested Restrictions provisions.

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HTI-1 Falls Short with DSI and Predictive Decision Support Proposals

By David Bucciferro, Chair, EHR Association

In other installments of this five-part blog series on the EHR Association’s issues with ONC’s Health Data, Technology, and Interoperability: Certification Program Updates, Algorithm Transparency, and Information Sharing Proposed Rule (HTI-1), we discussed our overarching concerns, as well as concerns with the Insights Condition program, transition to USCDI v3, and Patient Requested Restrictions. In this installment, we examine the considerable issues we have identified with provisions related to Decision Support Interventions (DSI) and Predictive Models.

According to ONC, the existing scope and structure of the Health IT Certification Program are to enhance transparency around predictive decision support, with requirements to make transparent information regarding the authorship, bibliographic, and other kinds of “source attribute” information for evidence-based decision support and linked referential interventions. Noting that AI/ML in healthcare “is often best considered a form of decision support or ‘augmented intelligence’,” ONC says its goal with the proposed rule related to DSI and predictive models is to update the existing decision support criterion to directly include predictive decision support, inclusive of ML technologies.

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HTI-1’s Insufficient USCDI v3 Transition Timeframe

In other installments of this five-part blog series on the EHR Association’s issues with ONC’s Health Data, Technology, and Interoperability: Certification Program Updates, Algorithm Transparency, and Information Sharing Proposed Rule (HTI-1), we discussed our overarching concerns, as well as specifics concerns with Insights Condition, the proposed requirements related to Decision Support Interventions (DSI) and Predictive Models, and Patient Requested Restrictions. In this installment, we examine issues with provisions related to the transition to USCDI v3.

More Time, Flexibility Needed

While we strongly support ONC’s efforts to advance USCDI in general, the proposed Jan. 1, 2025, development and implementation timeframe between the final rule and USCDI v1 expiration is far too short. It also needs to align with CMS timelines. Thus, we would like to see the deadline for USCDI v3 to be included in upgraded versions moved to the end of the second calendar year following the publication of the final rule (estimated to be Dec. 31, 2025). 

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HTI-1’s EHR Reporting Provision Puts EHR Developers in the Middle

By David Bucciferro, Chair, EHR Association

In previous installments of this five-part blog series, we examined the EHR Association’s overarching concerns with ONC’s Health Data, Technology, and Interoperability: Certification Program Updates, Algorithm Transparency, and Information Sharing Proposed Rule (HTI-1), as well as concerns with the transition to USCDI v3, proposed requirements related to Decision Support Interventions (DSI) and Predictive Models, and Patient Requested Restrictions. In this installment, we focus on our concerns with the HTI-1’s new Insights Condition and Maintenance of Certification Requirements provision.

According to ONC, Insights Condition fulfills a requirement in the 21st Century Cures Act for transparent reporting by creating a program to measure the performance of certified health IT (CEHRT) under a Condition and Maintenance of Certification. The goals of the EHR reporting program are to 1) address information gaps in the health IT marketplace and 2) provide insights on the use of specific certified health IT functionalities. 

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