3 Ways the 2015 EHR Certification Rules Will Change EHR Software

On March 30th 2015, a notice of proposed rules was issued by the Health and Human Services Department concerning EHR software certification. The proposed rulemaking introduces a new edition of certification criteria which includes, new standards and modification of the existing Office of the National Coordinator for Health Information Technology (ONC) Health IT Certification Program. From a broad perspective, the rule changes take on three areas concerning the functionality and certification of EHR technology.

Transitions of Care Enhanced Interoperability Functionality

ONC has expressed that facilitating Interoperability to support transitions of care (ToC) and increased options for the interoperable exchange of data is of the agency’s top priorities. Accordingly, ONC proposes a separation of the 2014 Edition’s ToC requirement to demonstrate both “content” and “transport” capabilities together. Functionally, this will enable these distinct capabilities to be separately tested and certified. Providers will also be able to implement these capabilities independently to meet the Certified EHR Technology (CEHRT) definition.

ONC further addresses a new “performance standard” for the receipt of electronic documents formatted in the Consolidated Clinical Document Architecture (CCDA) standard. The proposed benchmark requires EHR technology to process successfully validly formatted CCDAs no less than 95% of the time.

Non-MU Technology Certification

The proposed rules establish more flexibility under certification regulations allowing for the certification of “non-MU” EHR technology, thus allowing for Health IT certification for software with purposes beyond MU. For this type of technology which under the existing rules would not be eligible to qualify for MU incentive payments. The proposal departs from the current policy under which EHR technology developers must design EHR technology to meet MU-specific measure calculation requirements, even though, the EHR technology may not be used for MU. In response the agency proposed an “MU EHR Module” and “non-MU EHR Module” for certification to close this gap in the current rules.

Recommended Reading: EHR Vendor Directory - Find vendors complying with EHR certification rules

Discontinuation of the Complete EHR Definition

Further, the proposed rules appear to take steps to toward discontinuing the “Complete EHR” definition. The original CEHRT definition required a provider to have EHR technology meeting all the certification criteria appropriate to a care setting (ambulatory or inpatient). Previously, if a provider used a 2011 Edition Complete EHR, the CEHRT definition was satisfied. However, the CEHRT definition has been made more flexible for FY/CY 2014 and beyond with CEHRT status being expanded to EHR technology certified to the 2014 Edition.

This EHR technology would be required by ONC to meet the following criteria:

• 1. Meets the Base EHR definition (a finite set of capabilities)
• 2. Includes only the other capabilities that they need for the MU Stage they are attempting to achieve

The proposed changes found in the 2015 EHR Certification will likely impact vendors more than users due to the proposed rules’ emphasis on cleaning up some of the murkiness and redundancies in how the ONC classifies EHR. However, from the user’s perspective the clarity that will be gained from cleaning up these new regulatory classifications should make the process of working within the system of MU incentives considerably simpler.