In comments submitted to Dr. Karen DeSalvo, National Coordinator for Health IT, on the 2015 Edition Health Information Technology (Health IT) Certification Criteria Notice of Proposed Rulemaking (NPRM), the Healthcare Information and Management Systems Society (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 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. However, HIMSS stated that certification 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.
For new federal program-related health IT certification programs, HIMSS suggested that ONC or another agency establish the programmatic goals before commencing with any certification program associated with the effort. It is important that certification criteria be closely evaluated and aligned with the functionalities necessary to meet the goals of the program in question as the move continues beyond EHR-specific certification.
In its public comment letter, HIMSS also supported greater harmonization and alignment across the programs covered by certification. The Society cited anunderlying issue for health IT-related certification as the general complexity and multiple dimensions of harmonization and alignment required across federal programs. HIMSS recommended that any effort to address these issues would have to encompass more than just measures being harmonized—it would require coordination of timelines for programs and proposed rules, as well as various incentives and disincentives.
In addition, HIMSS supported the idea of including the level of adoption and maturity among standards as an important consideration when evaluating inclusions for certification programs.
The full HIMSS public comment letter on the 2015 Edition Health Information Technology (Health IT) Certification Criteria NPRM is available online.