- Industry groups are urging the Office of the National Coordinator for Health IT to consolidate existing health IT comparison resources in a centralized clearinghouse as part of the EHR Reporting Program mandated in the 21st Century Cures Act.
- Doing so would create a one-stop shop where end users could quickly access comparative information on a variety of certified health IT products, the American Health Information Management Association and National Rural Health Association wrote in separate comments on a request for information on the reporting program.
- Comparative information provided under the program should be user-friendly and presented in every-day language, the groups said. 'We recognize that the CHPL [Certified Health IT Product List] contains critical information designed to enhance transparency and accountability," AHIMA said. "However, end users may sometimes lack the technical background and expertise to fully comprehend the information presented on the CHPL, even though they play a critical role in the decision-making process around the acquisition, upgrade, or customization of a certified health IT product."
The Cures act tasks ONC with developing a reporting program that assesses characteristics of EHRs, including security, interoperability, usability and user-centered design, and conformance to certification testing. Yet more than 600 days since the law was enacted, industry is still awaiting details about the program and how it will work.
ONC issued the request for information amid growing pressure from lawmakers, including an amendment requiring the Trump administration to update Congress on progress being made around the information blocking provisions of the Cures Act. The amendment was adopted as part of the Senate fiscal year 2019 Labor-HHS appropriations bill.
While AHIMA supports development of the EHR Reporting Program, it recommends a step-wise approach that focuses initially on the mandatory reporting categories laid out in Cures. "AHIMA believes that a focused, incremental approach will help ensure that the comparative information developed under the program is usable and meets the needs of end users," according to its comments.
AHIMA also urged ONC to adopt naming convention strategies to ensure consistent terminology across all stakeholders, so that certified health IT products can be fairly compared. And comparative information made available via the reporting program should capture the full lifecycle of the product — from acquisition and implementation to maintenance, upgrades and replacement, the group said.
The American Hospital Association called for ONC to include reporting criteria that reflect a system's real workaday strengths and weaknesses. "Given the high adoption rate of certified EHRs, the EHR Reporting Program should emphasize reporting criteria that indicate how certified EHRs support the safe, efficient and effective collection, exchange and use of electronic health information rather than static certification criteria on collection of health information," the group said.
To do that, ONC could redirect reporting toward ways EHR performance supports clinical care, including new care models and patient engagement, AHA said.
Stakeholders also called for transparency both in the way reporting criteria are calculated and data obtained and regarding EHR costs. "While the methodologies used should be transparent, ONC should also ensure that the reporting criteria are not easily gamed — where submitting organizations curate data to derive a positive assessment that may not necessarily reflect the actual usability or safety of the system," NRHA wrote.
AHIMA and NHRA also suggested cost be a reporting category under the program. That would allow end users to compare not just initial costs of purchasing a health IT product, but subsequent costs associated with implementation, training, workflow design, upgrades, maintenance and transaction fees.
Commenters also urged ONC to adopt a least burdensome approach to the EHR Reporting Program, including using data collected from existing state and federal programs, where appropriate.
NRHA pushed for a "collect once, share many" policy of data collection.
In its comments, Cigna said it supports efforts to describe EHR functionality in terms of its setting, such as ambulatory care or outpatient surgery.
"We specifically support efforts to categorize platforms by their ability to provide needed data to support patient centered medical homes and support the provider's efforts to demonstrate compliance with requirements for documentation and data production imposed by various accrediting bodies," the health insurer said.
Comparative information should also include system stability issues with upgrades and patches, including stability of customization processes and how customization affects reporting capabilities, Cigna said. "Projected or known frequencies or upgrades and total cost of ownership for a given IT solution would be optimal," the company said.