CHIME to ONC: Don't overwhelm IFR with data transmission requirements

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Too many requirements on data transmission within an organization are not advised, according to the College of Healthcare Information Management Executives (CHIME) in its comments to the Office of the National Coordinator for Health IT (ONC) regarding the initial set of standards, implementation specifications and certification criteria for EHR technology.

CHIME commented on privacy and security standards included in the interim rule, particularly in areas of encryption and decryption of data, and verification of data to ensure it hasn’t been altered in transit and cross-enterprise authentication.

“Encryption of data in EHR databases and transactional systems would slow operation of the software, thus hindering adoption of EHRs by staff and physicians,” the organization stated. “We ask that ONC and the Centers for Medicare & Medicaid (CMS) carefully consider the risk vs. cost and performance issues during deliberations on this requirement.”

Comments on the interim final rule to ONC by the Ann Arbor, Mich.-based organization emphasized the importance of certification for supporting providers’ efforts to achieve meaningful use, which gives “healthcare providers a degree of assurance that the products they purchase will perform as promised…certification is meant to support providers, not pose an additional burden,” according to CHIME.

CHIME’s comments placed a fair amount of responsibility on vendors that develop IT products and urged ONC to provide more lead time as it creates future certification criteria, so as to provide more time for providers to implement new and upgraded systems in the future.

CHIME also noted that further clarification is needed in ONC’s interim final rule, particularly in describing how certification will apply to organizations that use multiple clinical systems as components of an overall EHR system. The organization stated that it supports wording in the rule that requires only certification of individual EHR modules.

CHIME asked ONC to support a single standard for patient summary records; the current interim rule allows use of either the HL7 Clinical Document Architecture (CDA) Release 2 (R2) Level 2 Continuity of Care Document (CCD) or the ASTM Continuity of Care Record (CCR) to electronically exchange a patient summary record.

“CHIME disagrees with this approach and believes that the sharing of health information across providers is best facilitated with adoption of a single standard for patient summary records,” the comment letter stated. “[T]he healthcare field is ready to transition to a single standard for patient summary records, and such a move will facilitate interoperability in a more timely fashion.” In addition, HL7 CDA CCD is more robust and easier to read, the organization stated.

According to the 1,400 member CHIME, medication reconciliation requirements in the interim rule need to be adjusted so that providers can meet the requirement if clinical systems can “display simultaneously two or more medication lists and provide tools for the clinician to perform medication reconciliation and create a single medication list.”

CHIME also noted that it seeks a standards-based approach for submitting data to public health agencies as current proposals for submitting data provide wide latitude to agencies for determining the format in which they want to receive data.

All of CHIME's comments to ONC can be found on the organization's web site.