Health IT stakeholders across the nation were recently asked to comment on criteria to define 2015 electronic health record (EHR) certification. Ostensibly, these criteria would allow EHR vendors to voluntarily certify their products to meet an updated set of standards by 2015.
Voluntarily? Even the Office of the National Coordinator (ONC), the party who issues the rule, admits that it expects such voluntary participation to be quite low. Why issue this proposed rule if only to make it voluntary? Perhaps to break ONC’s pattern of compressed regulation timelines by giving EHR developers an early preview of functionality that will be required for ONC’s upcoming 2017 certification rule, which in turn will be mandatory to comply with Stage 3 Meaningful Use. But even with that cushy deadline, industry stakeholders are pushing back.
Last week, the Electronic Health Records Association (EHRA) spoke out against the regulation, stating that “the proposed rule specifically does not respond to our repeated requests for final rules and all supporting materials and tools at least 18 months in advance of when providers and others expect certified products to be available.” (As if any other supporting evidence were needed for our decision last month to sever ties with this static group of software vendors.)
Unlike the EHRA, we appreciate this heads-up from the ONC. But as demonstrated by our 95.4% Meaningful Use attestation rate in 2013, our clients are thriving in the face of Meaningful Use requirements and timelines.
The ONC’s 2015 EHR Certification rule includes a handful of requirements that create tremendous value for both providers and patients—requirements such as more data-driven clinical decision support and advanced drug-drug and drug-allergy checks, to minimize the likelihood that patients are accidentally given prescriptions or procedures that may harm them. Is the industry really pushing back on this?
Not every requirement in the proposed regulation is perfect, of course, and frankly, some are outright awful, which I’ll show you some examples of later in the post. But the lens we use is not whether we have the time and resources to make changes (after all, this is 2014, if it still takes you 18 months to build and roll out elementary functionality, you are doing something wrong). Rather, we look at this rule in terms of the value it can bring to providers and patients, and ask whether the industry and government could invest in initiatives that will have even broader and more meaningful positive impact than the ones proposed.
Here’s an example: Consider that the rule calls on providers to be able to record a patient’s military service status, although it is wholly unimportant information for most clinical visits. Or that it suggests that providers record a patient’s occupation in a structured code, requiring providers to sort through a monstrous list of potential occupation codes. These are activities that only add to the time caregivers spend in front of their screen and away from patients.
Some requirements have even less value. One that’s associated with clinical quality suggests sharing a massive amount of granular patient information with the Centers for Medicare and Medicaid Services (CMS) for no apparent reason other than the technical ability to do so. Yet another revises—for the third time in four years!—the codes used to record a patient’s preferred language. Hardly the barn-burning tasks that will revolutionize health care.
What the national health care delivery system really needs is a true mandate for robust interoperability. Some of these capabilities are desperately needed, such as the ability to find a patient’s records wherever they may reside. What about creating provider directories to enable scalability of provider-to-provider and patient-to-provider electronic messaging? Where is the ability for providers to click a button and migrate all their data – clinical, quality, population health, patient communication – wherever they wish, without being held hostage by a poorly performing EHR? All of these critical pieces are superficially explored, if at all, in the proposed rule, but could prove so instrumental to the transformation of health care over the next few years.
To the ONC and the industry, we say: There is work to be done. We cannot and should not slow down… we are already far behind schedule. Let’s focus on pushing the boundaries of interoperability, openness, and clinical rigor. Let’s focus on the innovation it can enable, the silos it can break down, the lives it can improve, the costs it can eliminate. Now is the time to push. And push hard.