- HIMSS is calling for a six-month delay to the federal requirements for healthcare organizations and providers to use 2015 Edition certified EHR technology in the EHR Incentive Programs and Quality Payment Program.
In an April 11 letter to HHS Secretary Tom Price, MD, the organization cited delays in the availability of finalized test tools for software development and certification as warranting an extension of the deadline currently set for January 1, 2018.
“As of early April 2017, very few vendor products are certified to the revised 2015 Certification Criteria; this jeopardizes the requirement that health IT must be certified to the 2015 Edition for the Electronic Health Records (EHR) Incentive Programs and the Quality Payment Program (QPP),” wrote HIMSS leaders.
“We recommend moving the start date of the requirement to July 1, 2018, rather than January 1, 2018,” they continued, “to increase the likelihood that providers, vendors, and consultants have the necessary time to ensure products complete the certification process, are fully tested and implemented, and staff training and workflow adjustments are achieved to ensure safe, effective and efficient implementation and use of 2015 Edition Certified EHR Technology (CEHRT).”
HIMSS is calling for a six-month delay rather than a longer postponement based on its belief that industry-wide implementation of 2015 Edition certification to supporting healthcare transformation using health IT:
HIMSS supports the 2015 Edition Health IT Certification Criteria published in October of 2015. The 2015 Edition focuses on greater interoperability for clinical health purposes—opening up the certification program to other types of health IT, addressing health disparities, and including a new streamlined approach to privacy and security. In addition, the 2015 Edition Final Rule facilitates the accessibility and exchange of data by including enhanced data export, transitions of care, and application programming interface (API) capabilities. HIMSS supports the changes in the Final Rule, as they will help propel forward reforms to our healthcare delivery system and strengthen the ability of providers to share and exchange health information.
As part of the letter, HIMSS is recommending changes to both the EHR Incentive Programs and Quality Payment Program, which includes the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs) to “focus on furthering public health and safety, encouraging simplification, promoting innovation, and reducing workflow and reporting burdens on providers and developers.”
Per annual requirements for meaningful use and now MIPS and Advanced APMs, participating providers must use specific types of certified health IT to receiving positive or avoiding negative Medicare payment adjustments.
The organization noted that the 2015 Edition certification criteria publishing in published in October of that year did meet minimum requirements for preparing to implement a new set of standards.
“Although the 2015 Edition Certification Rule was finalized well in advance of our recommended 18-month threshold, unfortunately the healthcare community did not receive all of the finalized test tools that are required for software development and certification testing readiness until very recently,” the letter stated. “Given the limited time horizon in 2017 for the necessary implementation of the 2015 Edition, and to ensure that certified software is available for implementation, HIMSS believes that despite their best efforts, many providers will find meeting the January 1, 2018, requirement extremely challenging or impossible.”
According to HIMSS, the proposed delay is essential to ensuring for aligning health IT policy and infrastructure to achieve the goals of value-based care.
In late March, a group of provider associations led by the American Medical Association called on CMS Administrator Seema Verma to take additional steps to address challenges related to the EHR Incentive Programs, Physician Quality Reporting System (PQRS), and Value Modifier (VM).