In February, the ONC released a proposal for voluntary 2015 Edition criteria in an attempt to break the journey to meaningful use down into more manageable steps. However, the move has largely been derided by industry stakeholders.
The 2015 Edition criteria was the first certification criteria the ONC had proposed independently from CMS' meaningful use regulations and was part of an overall strategy to move to more frequent rulemaking. "The proposed 2015 Edition EHR certification criteria reflect ONC's commitment to incrementally improving interoperability and efficiently responding to stakeholder feedback," said National Coordinator for Health IT Karen DeSalvo, MD, in a statement.
Now, many stakeholders have responded, mostly to criticize the proposal.
HIMSS' Electronic Health Record Association, a coalition of EHR and related vendors, has urged the ONC to reconsider. The group believes the new criteria does not help the main stumbling block to meaningful use readiness — the crunched timeline. Not only would few vendors be able to update their software for 2015 implementations, having the 2015 Edition criteria as a stepping stone to 2017 Edition criteria does not address the providers' call to have the final criteria 18 months before providers would expect 2017 Edition products on the market, according to a letter the group wrote to Dr. DeSalvo in response to the proposal.
"Overall, we believe that the stated intention to move to more frequent certification… 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," stated the letter.
HIMSS itself has also written a letter to Dr. DeSalvo, expressing the same desire for the ONC to provide an 18-month warning for all new criteria as well as questioning the value of adding another set of certification criteria to the meaningful use timeline.
"Although the 2015 Edition certified EHR technology is proposed as a voluntary certification cycle, we are concerned that other federal programs and associated regulations (e.g., existing and new payment and delivery systems) could 'pick up' some or all of these requirements and incorporate them, thus turning a voluntary program into a mandatory program," stated the letter. "Overall, HIMSS stakeholders express unease and confusion in regard to both the timing and value of a more frequent certification cycle."
The American Hospital Association has also joined the chorus, urging the ONC and Dr. DeSalvo to focus on helping providers and vendors develop and implement workable products under 2014 Edition criteria rather than develop a new set of voluntary criteria.
"At this halfway point in the first year for stage 2, we strongly urge ONC to work with CMS to assess the number of Medicare EHR Incentive Program participants to date, the number that have attested to stage 2 and to swiftly publish guidance that informs hospitals how any relief, including 2014 hardship exceptions from the attestation requirement, will be operationalized," AHA leaders wrote in a letter to Dr. DeSalvo. "Publishing such guidance will address an immediate problem and will be more beneficial to providers than consideration of certification criteria applicable in fiscal year 2015."
Even the Telecommunications Industry Association, which represents communications vendors that work with a variety of industries, has expressed concern over the proposal.
"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," the group stated in a letter to Dr. DeSalvo.
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