Healthcare Information and Management Systems Society (HIMSS) EHR Association (EHRA) has requested federal officials to allow Stage 1 meaningful use providers to continue using sanctioned Stage 1 certified technology in 2014 in lieu of switching to an updated 2014 edition of certified technology.
In a May 3 letter to the Office of the National Coordinator for Health IT (ONC), HIMSS EHRA said, “As our members have carefully reviewed the development and operational implications of the proposed rules and reflected on our experience with Stage 1, we have concluded this challenging situation has been exacerbated in recent months due to the likely timing for the release of the Stage 2 final rule, the number and immaturity of the proposed clinical quality measures, the proposed certification criteria and that ONC calls for all providers to be required to upgrade to the 2014 edition of their EHR regardless of their stage of meaningful use.”
Bringing data into the discussion, HIMSS EHRA noted that the general consensus across the health IT community and by the Health IT Policy Committee is that 18 months are needed between release of the final rules and when providers need to upgrade.
“As of now, however, it is expected that this will be reduced to approximately 12 months for eligible hospitals and 15 months for eligible professionals,” the Chicago-based organization stated. “We therefore encourage ONC to consider allowing providers who are still in Stage 1 in 2014 to continue to use 2011 Edition certified EHR technology at their discretion.”
The EHR Association also made recommendations to improve ONC’s proposals regarding clinical decision support (CDS) and clinical quality measures (CQM), including:
- CDS functionality in an EHR should allow providers considerable flexibility in designing CDS, and they support allowing various scenarios within the definition of evidence-based interventions; and
- HIMSS EHRA supports the "calculate and transmit" aspects of the CQM criteria, but oppose the requirement to capture all data in the quality data model (QDM) and to export it using the vocabularies in the QDM, a substantial requirement well beyond the rest of meaningful use data capture and information exchange. “We recommend that one of the alternatives identified by ONC be adopted, such as a 'constrained' QDM, or a focus on only those data elements required for selected quality measures.”