The 2015 EHR certification criteria may be dead on arrival

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Talk about a lead balloon.

I don't know what caused the Office of the National Coordinator for Health IT to change its approach to certification and create a voluntary 2015 Edition of EHR certification criteria, but it doesn't seem to be going over well with stakeholders.

The government has received close to 200 comments on the proposed rule, released Feb. 21. According to the rule, the 2015 edition introduces the beginning of ONC's "new approach" to health IT certification regulations, updating the certification criteria every 12 to 18 months rather than waiting years, providing more incremental regulatory changes and enabling certification processes to more quickly adopt newer industry standards, spur innovation and fix bugs faster.

"EHR technology developers and EPs, EHs, and CAHs would have the opportunity to move ahead to the 2015 edition at their own pace and on their own terms," ONC says in the proposed rule. Comments were due April 28.

Many of the commenters took the opportunity to provide feedback on Stage 3 of Meaningful Use, for which ONC also solicited comments. For instance, several organizations, such as the Pew Charitable Trust and the Society of Thoracic Surgeons, supported a proposed criterion that would establish a new field in EHRs for unique device identifiers of implanted medical devices. The American Medical Association recommended that the entire Meaningful Use incentive program be "substantially overhauled."

But a deep dive into the comments reveals little support for the 2015 edition of certification criteria.  

Yes, some commenters provided feedback on the specific proposed criteria. But many of them came down strongly against the concept of the 2015 edition itself.

HIMSS' Electronic Health Record Association called it "costly" and "not desirable." EHRA warned that it moves away from interoperability and introduces complex new criteria with "minimal" provider demand that is not part of the recommendations made by the Health IT Policy Committee for Stage 3 of the Meaningful Use program.  The rule also provides a very short timeframe for vendors to design the software to meet the 2105 edition.

Kaiser Permanente disagreed with ONC's portrayal of the 2015 edition as an "incremental" and "small" update, questioned the need and value of voluntary certification criteria and warned that voluntary standards will be unpredictably imposed, create confusion and cause implementation conflicts. Kaiser "strongly" recommended that ONC not pursue the adoption and implementation of a 2015 edition.

The American Hospital Association warned that introducing voluntary compliance will complicate, rather than mitigate, the challenges providers have in using EHRs and introduces risk to successful attestation.

Even ONC's own Health IT Standards Committee weighed in against the 2015 edition, pointing out the cost burden to both vendors and providers and the "unclear benefit" to the provider community. The committee recommended instead that vendors focus on optimizing current code releases and begin preparing for Stage 3.

I don't know if ONC anticipated such a negative response from the public. But the fact that there was so much of it indicates that perhaps the idea should be revisited, if it's not already dead on arrival. - Marla (@MarlaHirsch @FierceHealthIT)

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