The Telecommunications Industry Association and American Medical Association are the latest groups to join a growing chorus of stakeholders opposed to ONC's proposed voluntary 2015 Edition of EHR technology certification criteria. In a letter to National Coordinator for Health IT Karen DeSalvo, M.D., TIA stated that while it generally supports the easing of certification by the issuance of voluntary criteria, the organization is concerned that the proposed rule for more frequent certification cycles could cause confusion and have unintended consequences.
The 2015 Edition represents a new approach for ONC which intends to update EHR certification criteria editions every 12 to 18 months in order to provide smaller, more incremental regulatory changes and policy proposals. But TIA, a trade association representing nearly 400 information and communications technology manufacturers and vendors, is not supportive of the proposed frequency of these updates.
"Although the 2015 Edition certified EHR technology is proposed to be voluntary, TIA is concerned that other associated federal programs and resulting regulations could reference or incorporate these voluntary requirements, thus subtly converting a voluntary program into a mandatory requirement," states the letter to DeSalvo. "Although TIA would be generally supportive of more frequent certification cycles as doing so would presumably maximize the use and implementation of innovative health information technologies; we remain in this particular instance cautious and offer that ONC move forward only after careful development."
Similarly, the HIMSS Electronic Health Records Association has railed against the proposed 2015 Edition arguing in their recent comments to DeSalvo that the group does not believe it is "necessary or workable to continue to issue certification criteria at a volume that would suggest the value of more frequent updates." Instead, EHRA advocates that post-2014 certification should be highly focused on interoperability and building on Stage 2 EHR criteria rather than introducing new functional criteria.
Likewise, the AMA this week sent a letter to DeSalvo expressing the concerns of its members that the meaningful use program is overly rigid and its certification process is not focused on ensuring interoperable and usable systems, and as a result it must be "overhauled so physicians can leverage technology to help ensure improvements in health care delivery.
For its part, TIA urged ONC to structure its 2015 certification criteria in ways that "maximize flexibility to permit evaluation of individual applications on their merits, in ways that account for the specific applicants needs." The group applauded ONC's clarification that developers who certify their EHR technology to the 2014 Edition will not need to recertify to the 2015 Edition in order for its customers to participate in the Medicare and Medicaid EHR Incentive Programs. At the same time, TIA urged the Centers for Medicare and Medicaid Services to be flexible in their evaluations and administration of eligible participant hardship exceptions.
The association's complete comments on the proposed rule can be found here.
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