- HIMSS and AMIA recently listed ways ONC can ensure the EHR Reporting Program supports interoperability improvements, health IT safety, patient health data access, and compliance with CMS value-based payment and quality improvement programs.
The associations submitted this feedback in response to an ONC request for information (RFI) issued in August.
Overall, HIMSS stated it supports ONC’s efforts to carry out the aims of the 21st Century Cures Act and create a public, transparent process for developing reporting criteria for inclusion in the EHR Reporting Program.
Offering stakeholders insight into the differences in EHR functionality between health IT products from different vendors can help to promote better-informed health IT purchasing decisions.
While HIMSS commended ONC’s interest in collecting and sharing health IT comparison data with EHR users, the society recommended ONC re-evaluate the list of comparison tools it plans to use to collect this data. Many of the tools ONC suggested using are no longer active, and others only provide limited data.
HIMSS also suggested ONC allow rural and underserved ambulatory and small practices to use low to no-cost comparison tools to promote equity between care settings.
“Additionally, it would be best to promote websites that provide information related to practice size, specialty, etc., to ensure that consumers can easily identify applicable technologies and tools, and the needs of the majority of consumers can be met,” advised HIMSS.
Collecting information from providers about the specific EHR system features that enable healthcare organizations to fulfill CMS reporting requirements for value-based payment and quality improvement programs would further strengthen the program, HIMSS recommended.
HIMSS suggested the EHR Reporting Program also provide data about the health data exchange and interoperability capabilities of EHR technology. Furthermore, HIMSS suggested ONC disclose information about each EHR developer’s efforts to reduce information blocking.
Offering providers access to information about each EHR vendor’s use of best practices standards from the Interoperability Standards Advisory Committee may also promote health data exchange among healthcare organizations.
To ensure ONC does not augment administrative burden on providers, HIMSS recommended the EHR Reporting Program leverage existing data already reported for other federal programs and other existing data sources.
Finally, HIMSS suggested ONC refine the EHR Reporting Program to address the relationship between EHR usability and health IT safety.
In its own comment letter, AMIA urged ONC to use live patient data to measure performance in the interest of improving the security, interoperability, and usability of certified EHR technology (CEHRT).
“Especially when viewed alongside the additional provisions in newly developed CEHRT Conditions of Certification, the EHR Reporting Program should be leveraged to bring transparency to how CEHRT performs in production environments with live patient data,” maintained AMIA.
“ONC should develop an EHR Reporting Program that more closely approximates a post-implementation surveillance ecosystem, not government-sponsored consumer reports,” the association continued.
The post-implementation surveillance ecosystem AMIA envisions would generate health IT product performance data automatically without requiring that users manually submit reporting criteria.
By including performance data in the EHR Reporting Program, ONC will be able to promote significant improvements in EHR system security, usability, and interoperability through market competition rather than only informing EHR purchasing decisions.
AMIA also recommended ONC develop interoperability reporting criteria, as well as measures that demonstrate an EHR system’s ability to provide patients with complete, digitized copies of their EHRs.
The EHR Reporting Program should also view health IT safety as a measurable byproduct of EHR usability, AMIA suggested.
Finally, the association urged ONC to align the EHR Reporting Program with other aspects of the Conditions of Certification mandated by Cures.
“Compliance with the EHR Reporting Program constitutes one of seven distinct aspects of new Conditions of Certification, so ONC should look for ways to enable participation in this program to meet these additional requirements,” stated AMIA.
HIMSS and AMIA join other stakeholders including Pew Charitable Trusts and the Arch Collaborative in submitting feedback to inform the development of the EHR Reporting Program.
The public comment period for the EHR Reporting Program closed October 17.