HIMSS Public Comment Letter to ONC on the 2015 Edition Certification Criteria Proposed Rule

In our comments on the 2015 Edition Health Information Technology (Health IT) Certification Criteria Notice of Proposed Rulemaking  (NPRM),  HIMSS thanked the Office of the National Coordinator (ONC) for the opportunity to work with its diverse membership to develop a coherent response to the 2015 edition certification criteria.  In addition, HIMSS recommended that ONC address the overall complexity of the 2015 Edition Certification Rule by reducing the total number of criterion, as well as the standards and functionalities included.

HIMSS also acknowledged that ONC and the Centers for Medicare & Services (CMS) strived to reduce the complexity of the requirements for the 2015 edition certification criteria and Meaningful Use Stage 3 in their respective NPRMs for this cycle.  However, given all the new requirements included in this NPRM, HIMSS asked ONC to reconsider the requirements needed for the 2015 edition certification criteria and consider approaches to minimize and simplify the options presented. 

Moreover, HIMSS cautiously supported ONC’s efforts to establish innovative certification and testing programs that utilize health IT.  HIMSS’ comment letter stated thatcertification in support of a Learning Health System must be specific, carefully planned, focused on the areas that have the greatest impact on interoperability, and closely aligned with programmatic goals.