Home > EHR, meaningful use, Medicare > ONC’s Proposed Rule on the Optional 2015 Edition EHR Certification Criteria Released for Public Comment

ONC’s Proposed Rule on the Optional 2015 Edition EHR Certification Criteria Released for Public Comment

Earlier this evening, the Office of the National Coordinator for HIT (ONC) made available its Notice of Proposed Rulemaking (NPRM, or proposed rule) to establish the optional 2015 Edition EHR certification criteria for HIT products used in the Medicare/Medicaid EHR Incentive Program.  The NPRM is currently on the Federal Register‘s public inspection desk and is scheduled to be formally published on February 26 for a sixty-day public comment period.

It is somewhat of an unorthodox NPRM in that portions of it deal with proposals for the 2015 Edition regulations, while the rest is comprised of RFI-style questions for use in informing the 2017 Edition rulemaking.  ONC noted in the preamble that they will not be addressing public comments submitted on 2017 Edition in the future 2015 Edition final rule. However, one of the challenges of incorporating 2017 Edition-specific questions in this NPRM is that those items are then technically viable for finalization in the 2015 Edition final rule per the Administrative Procedure Act.

The ACR Government Relations team is currently reviewing the NPRM and will work with ACR’s IT and Informatics Committee leaders on developing comments in the near future. Some of the proposals of interest for the 2015 Edition include:

  • Doing away with the “Complete EHR” certification status to emphasize modular certification.
  • Maintaining the exact same “imaging results accessibility” certification criterion as the 2014 Edition iteration.
  • Separating the three order types (meds, labs, and radiology) into separate CPOE criteria; something ACR has advocated for years to enable enhanced radiology CPOE software to obtain modular certification.
  • Requesting comments on (but not actually proposing for the 2015 Edition) the following three questions as they relate to imaging data and the “patient view/download/transmit” criterion:  1) whether images for patients need to be of diagnostic quality; 2) whether they should be viewable and downloadable; and 3) whether cloud-based technology could allow for a link to the image to be made accessible.
  • Overhauling the CDS criterion to align with the Health eDecisions initiative.
  • Recording user “ignore” responses to drug-drug/drug-allergy interaction alerts during medication orders and alerting sites like http://sideeffectsofxarelto.org if need be.

If you would like to submit comments to ACR for consideration and potential use in ACR’s future comments on this NPRM, please contact me at mpeters@acr.org / 202-223-1670.

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Categories: EHR, meaningful use, Medicare

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