Adding its voice to the EHR standards debate, the American Hospital Association asked for changes to proposed EHR standards, implementation, and certification.
The AHA sent its recommendations and comments regarding the interim final rule specifying the initial set of standards, implementation specifications, and certification criteria for EHR technology to the National Coordinator for Health IT in a March 15 letter.
The AHA made recommendations in five areas:
On EHR certification for meaningful use
The AHA believes:
- There needs to be "a clear distinction between the responsibilities of healthcare providers and the responsibilities of vendors of health IT products," as certification is intended to support providers, not impose an additional burden.
- Realistic timelines are necessary. AHA recommends one year between certification criteria finalization and vendor system certification, and an additional two years after certified products become available before providers must implement and/or use them to meet meaningful use criteria.
- The ONC should support CMS in creating a grandfathering provision for already-installed EHRs that permits providers to meet meaningful use criteria.
On implementation issues
The AHA offered the following commentary:
- While the interim final rule's definitions of EHR technologies in the interim final rule provide a solid framework for discussing certification, they don't take into account the complexity of EHR systems deployed in hospitals. Clarification is needed regarding which elements of an EHR system need certification and verifying that certain common practices will not necessitate additional or separate certifications.
- The AHA recommends that ONC specifically state the following: A hospital only needs to attest that its EHR system includes elements certified against the meaningful use objectives it must meet; a hospital's EHR system may also include auxiliary components and feeder systems that the hospital will use to meet meaningful use objectives, but do require separate certification; hospitals may install interfaces and programs to connect or complete EHR modules and related systems, but they do not require certification; hospitals may modify or customize certified EHR technology without needing additional certifications; and hospitals "will not be held responsible for having certified EHR modules for functionalities that no vendors support."
- The AHA believes there should be no requirement to conduct separate, on-site certifications for all best-of-breed systems or those composed of a base system with add-on components.
- The AHA encourages ONC and CMS to provide clear guidance establishing minimum requirements for hospitals to demonstrate an EHR is certified, and that those requirements be subject to notice and comment. AHA believes requiring hospitals to attest to their certification status is a legal compliance burden that could "result in significant penalties if hospitals and enforcement agencies have differing understandings of the specific requirements."