Further clarification is needed as to how certification will apply to organizations that use multiple clinical systems as components to an overall EHR, states CHIME in a comment letter to ONC regarding the Certification standards and implementation specifications IFR. CHIME supports wording in the rule that requires only certification of individual EHR modules.
Additionally, CHIME wants ONC to “place the lion’s share of responsibility (for certification) on vendors,” which it says builds on past experience in the healthcare IT space. The organization urges ONC to provide more lead time as it creates future certification criteria, so providers will be able to implement new and upgraded systems.
Further, CHIME asks ONC to support a single standard for patient summary records; the current interim rule allows use of either the Health Level Seven (HL7) Clinical Document Architecture (CDA) Release 2 (R2) Level 2 Continuity of Care Document (CCD) or the ASTM Continuity of Care Record (CCR) to electronically exchange a patient summary record. “CHIME disagrees with this approach and believes that the sharing of health information across providers is best facilitated with adoption of a single standard for patient summary records.”
Regarding medication reconciliation, the organization writes that the IFR must be adjusted so that providers can meet the requirement if clinical systems can “display simultaneously two or more medication lists and provide tools for the clinician to perform medication reconciliation and create a single medication list.”
When it comes to security, the organization states that the IFR places too many requirements on data transmission within an organization. “Encryption of data in EHR databases and transactional systems would slow operation of the software, thus hindering adoption of EHRs by staff and physicians. We ask that ONC and CMS carefully consider the risk vs. cost and performance issues during deliberations on this requirement.”