EHR Certification Proposal Stresses InteroperabilityEHR Certification Proposal Stresses Interoperability

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The Centers for Medicare and Medicaid Services (CMS) has posted its Notice of Proposed Rule Making (NPRM) for 2014 certification of electronic health record (EHR) technology. While the NPRM supports CMS' proposed Meaningful Use Stage 2 requirements in many different ways, its most important objective—and the linchpin of MU Stage 2 as well—is to increase the ability of EHRs to communicate with one another.

"Interoperability is what this is all about," said Laura Kolkman, president of Mosaica Partners, a St. Petersburg, Fla.-based consulting firm, in an interview with information Healthcare. "[The CMS proposal] is supplying the underlying technical infrastructure to get us to the point of being able to use better and more information to take better care of patients."

Specifically, the NPRM's interoperability elements include a new version of the Continuity of Care Document (CCD) as the single standard for clinical summaries to be used in transitions of care. Referred to in the NPRM as the Consolidated Clinical Document Architecture (CDA), this document includes 32 data elements that encompass all the fields that CMS deems essential. The same structured document will also be used to enable patients to "view, download and transmit" their health information as part of MU stage 2.

The key point here is that CMS has settled on a single standard. Noting that many EHR vendors are already supporting the CCD, Kolkman said, "That’s a big step in the right direction."

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Second, the NPRM requires the use of Direct secure messaging across enterprises. Developed more than a year ago by a public-private consortium, the Direct protocol has also been adopted by a number of EHR companies. "Direct is enabling better clinical communication, and it's a huge support to achieving Meaningful Use Stage 1," Kolkman said.

Third, the proposal requires EHRs to use the HL7 2.51 messaging format to submit reportable lab data, immunizations, and syndromic surveillance to public health agencies. Kolkman believes the impact of this might go well beyond public health reporting, because it could reduce the number of expensive interfaces that have to be written between EHRs and health information exchanges.

Fourth, the NPRM mandates the use of standard medical terminologies, including SNOMED CT for health problems and family histories, LOINC for lab results, and RxNORM for electronic prescribing. Although this won't have an immediate impact on providers trying to achieve Meaningful Use, it will play an important role in future efforts to improve interoperability and analyze EHR data, Kolkman said.

Aside from interoperability, the NPRM also makes it easier for specialist physicians to meet the Meaningful Use Stage 2 requirements. Instead of having to use a complete EHR or a collection of modules that meet all of the certification criteria, specialists now only have to use EHR technology that satisfies the requirements for them to achieve Meaningful Use. Specialists who don't need certain components of EHRs designed for primary care doctors can buy certified EHRs or modules that are tailored to their specialties.

There are eight new certification criteria that support MU Stage 2 objectives in both inpatient and ambulatory care settings. These include electronic documentation of visit notes and family histories, the ability to view images, the ability of patients to view, download, and transmit their health information, and user-centered design features to enhance safety.

To protect the privacy and security of personal health information, CMS proposes that all data be encrypted by default on any device used to store data.

The NPRM also explains that EHRs do not have to be re-tested for features that were included in the 2011 certification criteria. Providers can continue to use 2011 edition-certified EHR technology until the end of 2013. Starting in 2014, when stage 2 requirements go into effect, they will have to use 2014 edition-certified EHRs.

Overall, Kolkman said that the Meaningful Use Stage 2 and EHR certification proposals show that CMS "is getting a healthy dose of reality about how much it's taking to get our healthcare system and health IT to where it needs to be. We can't get there as fast as we want to from both a health management perspective and a cost of doing business perspective. The feds are listening to the industry and the providers, and that's why we're seeing them provide more flexibility to meet their requirements."

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