Insight and Input on ONC’s Proposed Roadmap for EHR Technology: ONC Issues Proposed 2015 Edition of Meaningful Use EHR Certification Criteria

by Davis Wright Tremaine LLP
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On Feb. 21, the Office of the National Coordinator for Health Information Technology (“ONC”) released a proposed rule for voluntary 2015 Edition EHR certification criteria for the Medicare and Medicaid meaningful use incentive programs and changes to the ONC HIT Certification Program. The 2015 Edition would be voluntary both for EHR vendors for purposes of meeting the certified EHR requirements in the meaningful use programs, and for providers participating in the programs with regard to the EHR technology they use to accomplish meaningful use. Because ONC plans on releasing a mandatory update to the EHR certification criteria effective in 2017, the proposed 2015 Edition criteria provides an opportunity for both insight and input on the standards, implementation specifications and criteria that are likely to become mandatory for 2017.

With the release of this proposed rule, ONC intends to issue more frequent, incremental rules regarding EHR certification criteria in order to give EHR technology developers more time to plan, develop and implement EHR technology updates. If EHR developers elect to implement voluntary certification requirements over time prior to their becoming mandatory, users may experience more gradual updates instead of facing periodic major systems upgrades.

Some of the changes to the EHR certification criteria and HIT certification program would:

  • Require every EHR technology certified to the transition of care objective to transmit data in accordance with the Applicability Statement for Secure Health Transport (the primary Direct Project specification);
  • Adopt the Health eDecisions standards and require their use in connection with processing, requesting and receiving clinical decision support guidance;
  • Require EHR technology to be capable of filtering of clinical quality measures (CQM) results by patient population characteristics, such as practice site and address; provider identification number, diagnosis, health insurance coverages including Medicare/Medicaid eligibility, and demographics;
  • Establish certification packages to reflect groupings of certification criteria, beginning with “care coordination” and “patient engagement”; and
  • Allow certification for EHR technology intended for settings where providers do not typically qualify for participation in the meaningful use programs, such as behavioral health or long-term post-acute care settings, thus creating a category of “Non-MU EHR Modules.”

In addition, the proposed rule solicits public comments on many other ideas under consideration for the eventual 2017 Edition criteria, such as:

  • Options for how privacy and security criteria could be applied to the certification of EHR Modules;
  • Whether, and what, standard to adopt for oral liquid medication dosing; and
  • The potential adoption of a “Blue Button +” criteria for the ability to get patient records in a human-readable and machine-readable format, and allowing the patient to send them where they choose.

This proposed rule allows both EHR developers and real-world users—professionals and hospitals—to weigh in on what the future of EHR technology should be. The deadline for public comment is April 28, 2014.

 

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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