In letter to Department of Health and Human Services (HHS) Secretary Tom Price, the Health Information and Management Systems Society (HIMSS) recommended delaying the start date that requires providers to use 2015 edition certified electronic health records (EHRs) as the organization is concerned about the implementation timeline for the 2015 Edition Health IT Certification Criteria.
HIMSS recommends moving the start date to July 1, 2018, rather than January 1, 2018, to “increase the likelihood that providers, vendors, and consultants have the necessary time to ensure products complete the certification process, are fully tested and implemented, and staff training and workflow adjustments are achieved to ensure safe, effective and efficient implementation and use of the 2015 Edition.”
HIMSS also voiced its concern about the current level of available certified vendor products. “As of early April 2017, with very few vendor products certified to the revised 2015 Edition Certification Criteria, HIMSS voiced unease with the requirement that health IT must be certified to the 2015 Edition for the Electronic Health Records (EHR) Incentive Programs and the Quality Payment Program (QPP) beginning on January 1, 2018,” Michael Zaroukian, M.D., Ph.D., chair of the HIMSS America board of directors, and H. Stephen Lieber, president and CEO of HIMSS, wrote in the letter.
HIMSS leaders stated in the letter that the organization supports the 2015 Edition Health IT Certification Criteria, which was published in October of 2015. “The 2015 Edition focuses on greater interoperability for clinical health purposes—opening up the certification program to other types of health IT, addressing health disparities, and including a new streamlined approach to privacy and security,” Zaroukian and Lieber wrote. And, HIMSS also reiterated its support of EHR Incentive Programs and QPP, as well as the overall health IT certification program process.
HIMSS has repeatedly requested 18 months as the minimum length of time needed between the release of final rules on Meaningful Use, certification criteria, or standards, and the start of a new program-reporting period. “The 18- month period allows stakeholders time to educate and prepare providers on the requirements of the upcoming reporting period,” HIMSS wrote.
Zaroukian and Lieber also note that while the 2015 edition certification rule was finalized in advance of HIIMSS’s recommended 18-month threshold, the healthcare community did not receive all of the finalized test tools that are required for software development and certification testing readiness until very recently.
“Given the limited time horizon in 2017 for the necessary implementation of the 2015 Edition, and to ensure that certified software is available for implementation, HIMSS believes that despite their best efforts, many providers will find meeting the January 1, 2018, requirement extremely challenging or impossible. The circumstances warrant a six-month extension,” HIMSS stated.
HIMSS leaders also wrote that changing the implementation timeline requirements of the 2015 Edition Health IT Certification Criteria is “an important opportunity to realign our regulatory system to meet our provider community’s real-world needs, improve their overall user experience, and decrease EHR stress as a contributing factor to clinician burnout.”