Cavanaugh Consulting Group

Message to ONC – Change the current EHR certification process

In a Jan. 21 letter (9 page PDF) to Karen DeSalvo, M.D., M.P.H., director of the Office of the National Coordinator for Health Information Technology (ONC), the AAFP and 41 organizations representing hundreds of thousands of physicians nationwide, urged the ONC to consider seven changes to the current EHR certification process. Members often described their EHR systems as “cumbersome” and unable to meet workflow needs. The letter recommends:

    1. Decouple EHR certification from the Meaningful Use program; “excessive burdens on physicians and their practices” because they tie successful compliance to measures that require “specific patient participation, cumbersome data collection and complex exchange methods.”
    2. Re-consider alternative software testing methods; “We believe the best way to ensure high-performing EHRs and to minimize errors is to rigorously test them against a multitude of clinical scenarios that represent the variety of workflows seen in acute and ambulatory care settings,”
    3. Establish greater transparency and uniformity on UCD testing and process results; “Although an ONC Federal Advisory Committee explored the use of this framework in the past, scenario-based testing was excluded as a requirement for 2014 EHR certification.”
    4. Incorporate exception handling into EHR certification; identifying exactly how software would handle human error such as entering inaccurate information — should be used in tandem with testing in clinical scenarios.
    5. Develop C-CDA guidance and tests to support exchange; The variability in C-CDA construction causes a mismatch between the sending and receiving EHRs and limits the usefulness of information that is actually viewed by the physician and other medical professionals at the point of care,
    6. Seek further stakeholder feedback; convene a “software certification learning session” that would involve individuals from a variety of fields with experience in producing, testing and certifying software.
    7. Increase education on EHR implementation. The groups urged DeSalvo to consider a semi-annual roadshow to disseminate ideas about implementing and deploying EHRs. “As the very least, educational activities should be conducted after each new EHR certification version,” the letter concluded.