The HIMSS Electronic Health Records Association has voiced concerns to the Office of the National Coordinator for Health IT on proposed criteria for the voluntary 2015 Edition of meaningful use.

Representing more than 40 companies, the group takes issue with the cost of meeting and being certified on additional levels of certification. Published Feb. 26 in the Federal Register for public comment, the 2015 Edition is a new approach for ONC which going forward intends to update certification criteria editions every 12 to 18 months to provide smaller, more incremental regulatory changes and policy proposals.

However, in a letter to National Coordinator Karen DeSalvo, M.D., the EHR Association argues that ONC's proposal "moves in the opposite direction from our request for adequate time to deliver high quality software, and for our customers to prepare to use it in a meaningful and safe way." Further, the group argues that post-2014 certification should be highly focused on interoperability and building on Stage 2 EHR criteria rather than introducing new functional criteria.

"We simply do not believe that it is necessary or workable to continue to issue certification criteria at a volume that would suggest the value of more frequent updates," states the association's letter to DeSalvo. "We also do not believe that more frequent formal certification editions are needed to make technical changes or to enable use of updated standards, which we believe can be done via FAQs, technical corrections, or within existing authority."

The EHR Association also expressed concern about the "compressed timeline" for continued improvements to the electronic clinical quality measure process, which "does not allow adequate time to ensure that the critical improvements already underway to the Clinical Quality Measures development, testing, and implementation process continue to advance, and are not compromised by rapidly changing standards and requirements that are only just evolving."

While supporting the efforts by both the Centers for Medicaid and Medicare Services and ONC to improve the eCQM development and implementation process, the group charges that the inclusion of this framework in 2017 Edition certified software (Stage 3) is "not feasible" because it does not leave enough time for ensuring that all affected processes are fully addressed. There is not time to re-engineer the measure authoring tool, the current CQM specifications, and develop new CQM specifications, according to the association.

"The EHRA therefore strongly urges ONC not to include the proposed unified Clinical Decision Support/Clinical Quality Measures standards for 2017 CEHRT," states the letter. "We urge ONC and CMS to consider a more incremental approach to the eventual implementation and adoption of these standards, ensuring that each one has been fully tested and piloted prior to requiring adoption by all EHRsThe association's detailed 67-page response to the proposed rule can be found here.

Last month, ONC made corrections to its proposed rule for the 2015 Edition of EHR technology certification criteria. In a March 19 Federal Register proposed rule, ONC's Federal Policy Division Director Steven Posnack corrected the preamble text and gap certification table for four certification criteria that were omitted and provides information on inactive web links that appear in the proposed rule.

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