Certain criteria and standards in the Certification and Implementation IFR may represent “a step backwards in progress toward EHR interoperability, by dropping standards that were already federally recognized and widely adopted, while other criteria demand an unrealistic leap forward,” stated CCHIT in a recently filed comment letter to CMS.
“… the criteria and standards need refinement … ,” states Mark Leavitt, M.D., chair. The commission is “concerned about the possibility of an unintended deceleration in the pace of EHR adoption.”
The comments highlight two other broad concerns:
- “The scope of a ‘Complete EHR’ inappropriately includes administrative and billing functions, diverting funds and effort into unnecessary certifications of already-installed billing systems for every doctor and hospital seeking the EHR incentives.”
- “Some IFR criteria define required functions of an EHR too microscopically, adding unnecessary costs and complexity, and creating barriers to innovation.”
The Commission also commented on the regulatory impact analysis required as part of the rule making process. While the IFR concludes that the new rules would not impact a significant number of small businesses, the Commission supplied data and analysis indicating the impact would be very substantial.
To discuss its comments, CCHIT plans a Town Call on March 18 at 4 p.m. Eastern. Also on the agenda will be its progress and plans in light of the Certification Process NPRM published by ONC on March 10.