CMS released the draft 2015 Edition Electronic Health Record (EHR) Certification Criteria for comment.  The certification criteria are the rules that vendors who provide Certified EHR Technology (CEHRT) must follow in order to have their products certified for Meaningful Use / MIPS. 

Adherence to the final 2015 certification standards will be voluntary for vendors who have already certified their products to the 2014 standards, and by extension, providers will not have to upgrade their EHR software to 2015 edition compliant versions.

Over half of the requirements are unchanged from the 2014 edition of the standards —15 percent of the proposed requirements are completely new, with the balance being modified when compared with the 2014 edition. The high degree of unchanged requirements is particularly significant because of the “gap certification” program that allows vendors to rely on previous certifications for unchanged rules, simplifying the certification process, and hopefully bringing certified products to general release sooner.

As healthcare providers, the certification standards don’t directly apply to us – our EHR vendors have to meet the standards with their product,  but that doesn’t mean that there’s nothing of interest in the document. A provider can learn some things about future direction of Meaningful Use / MIPS and potential Stage 3 criteria by examining the draft standards. It’s a long rule, nearly 250 pages, and while many of the certification standards are fairly technical, e.g. changes in version of various code sets, there are standards that will impact provider activities in the future.

Here is a summary:

• New criteria supporting filtering of clinical quality measures based on patient population. This enables providers to document outcomes of quality measures directed at a specific population.
• Revisions to the demographics standards to support recording a patient’s preferred language and recording a patient’s date of death and the preliminary cause of death. There is also a request for comments on whether the patient’s preferred language should be taken into account when producing patient education documentation.
• Revisions to the Clinical Decision Support (CDS) standard requiring the ability to use demographic data such as patient sex as part of a CDS rule.
• New criteria for the structured recording of family history
• New criteria to support inclusion of unique device identifiers (UDI) for implantable devices.

The draft standards also contain numerous tweaks to various standards used for the creation, transport, and recording of clinical communications like lab results and Transition of Care documents. It’s very clear from the draft certification that the communication between clinical providers will continue to be a high priority in future MU standards. Providers should expect more aggressive requirements for such communications in the Stage 3 rules when they are released.

The draft 2015 Edition EHR Certification Criteria will be open for comment for 60 days,  and the final rule is expected in the summer.

After reading this, what should providers consider as they continue their current Meaningful Use / MIPS efforts?

CMS has often stated that Meaningful Use / MIPS Stage 3 will be about outcomes.  The proposed changes to the clinical quality measures and clinical decision support measure directly support these changes.

We will continue to see inclusions of more kinds of data, like UDIs and structured family history, as EMR technology matures.

Technologies already in place, like transmission of data to public health agencies or other health care providers will become increasingly more important in future versions of the rules, with higher percentages required for attestation, and more advanced features required. Providers should focus on building dependable and expandable work processes now, so that future increases in the standards won’t require a complete retooling of the processes.

Developing and deploying Meaningful Use / MIPS processes that work is highly dependent on the contributions of the nursing and physician staff. IT departments whose working relationships with the nurses and physicians are strained need to focus on this first, as this relationship is the foundation on which successful EMR usage is built.

Phoenix’ experienced consultants help clients just like you to map an appropriate strategy and then implement Meaningful Use / MIPS every day. Contact us here, for more info >>