HIMSS Submits Comments on ONC’s EHR Reporting Program Proposed Regulation

HIMSS Submits Comments on ONC’s EHR Reporting Program Proposed Regulation


On Wednesday, October 17, HIMSS submitted a letter on the Office of the National Coordinator for Health IT’s (ONC’s) Request for Information Regarding the 21st Century Cures Act Electronic Health Record (EHR) Reporting Program that articulated appreciation for the agency’s proactive approach to create a public, transparent process to establish the reporting criteria associated with the EHR Reporting Program. HIMSS was encouraged by ONC’s efforts to ensure all stakeholders have more information on the functionalities and differences between health IT products and are fully informed about industry trends on business process decision-making.

Overall, HIMSS believes there is significant knowledge to be derived from collecting health IT comparison information and the HIMSS letter recommended that ONC re-evaluate the list of comparison tools identified through its market research as many of the tools are no longer active, while others are limited in the data they provide. In HIMSS’s experience, creating a resource that is useful to a broad range of purchasers is beneficial, but difficult to maintain.

In addition, the letter identified rural or underserved ambulatory and small practices as those settings that would benefit most from low to no-cost comparison tools and HIMSS encouraged ONC to promote websites that provide information related to practice size, specialty, etc., to ensure that consumers can easily identify applicable technologies and tools, and the needs of the majority of consumers can be met.

Moreover, HIMSS thought that it would be useful if ONC were to collect information from providers on the specific features of an EHR and other clinical systems that directly contribute to providers’ ability to meet requirements for value-based payment and/or quality improvement programs through CMS.

The HIMSS letter also highlighted the importance of data transmission to the functioning of an EHR and HIMSS would like to see the EHR Reporting Program tool provide information on how successful a product is at transmitting usable information to an outside system and whether the developer or the provider put sufficient policies and procedures in place to mitigate any sort of risk related to information blocking.

HIMSS also suggested that this program provide information related to if the developer is using recognized, updated, best practice standards as noted in the Interoperability Standards Advisory. The HIMSS response noted the variety of data already available via the Certified Health IT Product List (CHPL), including subjective usability task ratings, and other health IT comparison websites that are useful in reporting criteria from both the developer and end-user to inform health IT comparisons.

The reduction of additional burden on clinicians is critical to having a successful EHR Reporting Program, and HIMSS strongly encouraged the continued use and repurposing of data already reported for various federal programs. HIMSS stated its belief that a statistically viable amount of patient data should be centralized and made available via the Health IT Playbook and HIMSS strongly encouraged using existing data sources and educating the healthcare industry about the availability of the data as well as helping the market understand how to interpret it, including easily accessible links to these data sources.

To appropriately address safety, HIMSS urged ONC to further refine the EHR Reporting Program to address health IT safety factors, particularly in the usability aspects, and capitalize on existing efforts that focus on the safety components of health IT implementation and programs that shed light on the safety of EHRs.

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