HIMSS Recommends that HHS Move the Start Date of the Requirements Around Using 2015 Edition Certification Criteria

In an April 11th letter to Department of Health and Human Services (HHS) Secretary Tom Price, HIMSS recommended moving the start date for the requirements around using the 2015 Edition Health IT Certification Criteria 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 noted increasing concern with the current level of available certified vendor products, as well as the implementation timeline for, the 2015 Edition.  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.  

In addition, the HIMSS letter stated that the July 1, 2018, start date was purposely chosen to be the recommended start date of the 2015 Edition requirements, rather than a later date, to reinforce the importance of adopting the criteria and to fulfill our commitment to health IT supporting healthcare transformation.  

Moreover, HIMSS reiterated strong support for the 2015 Edition Health IT Certification Criteria, and its focus on greater interoperability for clinical health purposes, opening up the certification program to other types of health IT, addressing health disparities, a new streamlined approach to privacy and security, and application programming interface (API) capabilities.  HIMSS also expressed support for the EHR Incentive Programs and QPP, as well as the overall health IT certification program process.  

In previous federal regulatory public comment letters, HIMSS 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.  Although the 2015 Edition Certification Rule was finalized well in advance of the recommended 18-month threshold, unfortunately 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 remaining in 2017 for the necessary implementation of the 2015 Edition, and to ensure that certified software is available for implementation, HIMSS was concerned that despite their best efforts, many providers will find meeting the January 1, 2018, requirement extremely challenging or impossible.