No, your eyes are not betraying you…this week’s blog topic is not on MACRA, MIPs, or APMs! With a long holiday weekend coming to a close, I thought I would give you a bit of a reprieve from the MACRA madness.
Instead, let’s turn our attention to another ruling made final last October, the ONC 2016 Health IT edition certification.
What is certification?
For those unfamiliar, the Office of the National Coordinator for Health Information Technology (ONC) Health IT Certification Program is a voluntary program established by the ONC to provide for the certification of health IT standards, implementation specifications, and certification criteria adopted by the Secretary.
The overarching goal of the ONC is to ensure the following goals are met through the certification of health systems:
- Improve Interoperability
- Facilitate Data Access and Exchange
- Ensure Privacy and Security Capabilities
- Improve Patient Safety
- Reduce Health Disparities
- Improve the Reliability and Transparency of Certified Health IT
- Use the ONC Health IT Certification Program to Support the Care Continuum
- Support Stage 3 of the EHR Incentive Programs
Getting certified isn’t something a clinician or practice has to do (for once)—your EHR vendor will be the one doing the heavy lifting here. However, at the end of the day, a clinician will need to use most parts of a 2015 ONC certified EHR technology (CEHRT) in order to avoid a negative payment adjustment. EHR use is one of the main components to the Quality Payment Program, with both MIPS and APMs requiring the use of a CEHRT.
The criteria
Most EHRs will certify to meet the “base EHR definition”. A base EHR focuses, at a minimum, on the functionalities that all users of certified Health IT should possess.
In addition, CEHRT must also be able to exchange key health data known as the Common Clinical Data Set using specified vocabulary standards when applicable. This will allow systems to “speak the same language” when sending and receiving patient data.
All providers using a 2015 ONC edition CEHRT should be able to electronically send the following clinical information about a patient:
- Smoking Status
- Procedures
- Problems
- Care Team Members
- Medications
- Immunizations
- Medication Allergies
- Implantable Devices
- Laboratory Tests (along with Values/Results)
- Assessment and Plan of Treatment
- Vital Signs (Height, Weight, BP, and BMI)
- Goals
- Care Plan (including Goals and Instructions)
- Health Concerns
Well, that doesn’t look too hard. Shouldn’t an EHR already do this? Why, yes, but of course there’s more! To support meaningful use stage 3 the Advancing Care Information requirements (ACI) of MIPS, a system will also need to meet the following criterion:
- Patient-Specific Education Resources
- Transmission to PHA—Antimicrobial Use and Resistance Reporting
- Electronic Prescribing
- Transmission to PHA—Syndromic Surveillance
- Transmission to Immunization Registries
- Patient Health Information Capture
- Secure Messaging
- Transmission to PHA—Electronic Case Reporting
- Transmission to PHA—Health Care Surveys
- View, Download, and Transmit to 3rd Party
- Transmission of Cancer Registries
- Clinical Information Reconciliation and Incorporation
- Drug-Drug, Drug-Allergy Interaction Checks
- Drug-Formulary and Preferred Drug List Checks
- Trusted Connection
- Safety Enhanced Design
- Quality Management System
- Family Health History
- Auditing Actions on Health Information
- Clinical Quality Measures—Report
- Auditable Events and Tamper-Resistance
- Automated Numerator Recording
- Automated Measure Calculation
- Integrity
- Accessibility-Centered Design
- Consolidated CDA Creation Performance
- Clinical Quality Measures—Import and Calculate
- Authentication, Access Control, Authorization
- Audit Report(s)
- Amendments
- Automatic Access Time-Out
- Emergency Access
- End-User Device Encryption
Listing out all the criteria makes it seem somewhat trivial—if it were only so! ONC put together a summary slide deck for those interested in learning more. Or, if you are really bold (or bored) you can read the hundreds of pages of test procedures and guides that accompany each criterion here.
You’re adding that? That’s not what I wanted!
This is a phrase I’ve heard all too often throughout the last 6 years of chasing ONC certification. As you can see from the lists above, there is a constant battle between regulation and innovation.
This puts vendors in the middle of a rock and a hard place.
With a new payment model lurking around the corner, the marketplace will demand innovative solutions to help clinicians come out ahead. All the while, the health IT industry will see a declining market share due to more consolidation of smaller practices and groups, meaning vendors may have fewer development resources. Layer in the regulatory demands that will consume the lives of most vendors for the next year and you’ve created a perfect storm!
I believe one of the best analogies belongs to the CIO of Beth Isreal, John Halamka, MD, who compared the whole conundrum to a game of beer pong, “The more you miss, the more you drink, the more you miss.” In other words, the more regulation, the fewer new sales, the less ability to deal with regulation.
What’s the timeline?
All clinicians participating in MIPS (and a majority going down the advanced APM path) must have a 2015 edition CEHRT in hand by January 1, 2018. Thankfully, for the 2017 reporting period, CMS will still allow the use of your 2014 edition certified EHR.
With so much uncertainty in the air with MACRA, it is doubtful that EHRs will rush to get their products certified. Even though the ONC 2015 edition certification rule is final, the MACRA rule isn’t and could change the certification criterion in which a vendor would want to certify. If the final MACRA rule reduces a large number of measures a clinician needs to meet for MIPS, vendors will probably choose not to meet the criterion associated with those measures. With this year also being an election year, one may wonder what MACRA and ONC certification will look like if Trump were elected?
The most important thing to do now is to keep up with the changes your EHR vendor will be making to prepare for certification. And if your vendor isn’t planning to certify, you may want to start asking some questions!
Diana Strubler, Policy and Standards Senior Manager, joined Acumen in 2010 as an EHR trainer then quickly moved into the role of certification and health IT standards subject matter expert. She has successfully led Acumen through three certifications while also guiding our company and customers through the world of Meaningful Use, ICD-10 and PQRS.
Mark Hayes says
Diana – thanks for the great blog post, I’m glad to see more focus on the ONC 2015 rule. I have a question regarding this quote from your post: “With so much uncertainty in the air with MACRA, it is doubtful that EHRs will rush to get their products certified. Even though the ONC 2015 edition certification rule is final, the MACRA rule isn’t and could change the certification criterion in which a vendor would want to certify. If the final MACRA rule reduces a large number of measures a clinician needs to meet for MIPs, vendors will probably choose not to meet the criterion associated with those measures.”
Are you aware of any cross walk summarizing the connection between the Advancing Care Information measures in the proposed MIPS rule with the corresponding ONC 2015 certification criterion? I’m trying to get a better understanding of what ONC 2015 certification criterion are likely to be required to meet MIPs and which ONC 2015 certification criteria will be considered outside the scope of MIPs. Thanks.
Diana Strubler says
Hi Mark,
I am not aware of a crosswalk for ACI and ONC certification. The only thing I have seen thus far is the MU stage 3 to ONC crosswalk.
However, the only ONC test procedures that will have a direct correlation with the MACRA final rule are: (g)(1) Automated numerator recording and (g)(2) Automated measure calculation.
If you go to the healthit.gov website listing all of the test procedures (https://www.healthit.gov/policy-researchers-implementers/2015-edition-test-method) you will see that they even made a note that testing bodies should hold on testing those two items until the MACRA rule is final.
I would go out on a limb and say that the remainder of the test criteria that defines a “certified system” will remain required and unchanged.
I am wondering if they will add any additional certification criteria to help define how the ACI category and new CPIA category of MIPS will work in terms of submitting data to CMS via an EHR.
To make things more interesting – there is talk that the final rule may not be released as soon as we thought (and MIPS could be delayed). Fun stuff!
Diana Strubler