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Monday, March 23, 2015

What to worry about in the MeaningfulUse 2015 Certification NPRMs

After two weeks of 12-hour a day training (which is why this blog has been uncharacteristically quiet), I was awarded Friday by ONC with way to many pages to read, just like everyone else.  I'm barely 25% done on the Certification rule, but many have already asked for my views and observations.  Here is what I know so far:

There are 67 certification criteria, up 18 criteria from 49 last cycle.  The criteria has been rewritten to apply all of Health IT, not just EHR systems.

The Clinical Criteria

Within the clinical criteria sub-section 170.315(a) there are 23 criteria, 7 are unchanged, 11 revised, and 5 new criteria.

Things you don't have to worry about: CPOE for Medications and Imaging, Medication and Medication Allergy Lists, Imaging Results, Patient List Creation, and Electronic Medication Administration Records.

After updating your vocabulary to the new standards, you also don't have to worry about these:
Demographics, Problem Lists, Smoking Status, and Family Health History.

Now, start worrying, but not too much yet:

Simple Stuff

Vital Signs just got a little more complicated, but for anyone who has been following HITSP, IHE, CCD, C32 or C-CDA specifications, these are pretty simple upgrades.  There are a few new "vital sign" codes that can be applied for dealing with BMI, or oxygen saturation, but for the most part, this is pretty straightforward stuff.

Drug/Drug and Drug Allergy and Intolerance checking also got a bit more complex, in that now you are expected to record what providers do with those alerts.  If you haven't instrumented them already, you will be expected to do so.  This is also fairly simple and obvious.

CDS adds the same requirement to record what providers do in response to an intervention, again, not a big lift.

On requesting patient specific education resources, a new requirement that they be able to be requested in the patient's preferred language has been added.

Moderately Challenging

Among the moderately challenging requirements, the following have been added or revised:

Lab CPOE is about to get harder, and easier.  There are new standards to apply for the compendium, and the order.  In general though, this one is a wash, PROVIDED we can get labs (which have NO incentives to use MU standards) to start using them.  This will be work, but also have value for everyone under that proviso.  

If you don't already support the HL7 Pedigree standard, the new rule splits it out as a separate criterion.  It won't be as hard as say, the C32 or the C-CDA, but it will be challenging if you have to do it to support the CMS rule for your customers (I haven't even cracked that one open yet, so I don't know what the ramifications are for that).


They've changed capturing Advance Directives to capturing details about other documents, such as birthing plans.  The rationale sounds good, but I'm not sure the two really want to work the same way, especially given the new care planning work in C-CDA Release 2.0*.

Drug Formulary and Drug List Checks will also be on the more difficult side if you haven't already adopted the NCPDP Formulary and Benefit Standard v3.0 standard that was part of the voluntary criteria.

Populating the Implantable device list is probably going to include a whole new set of user interfaces for folks.  I know of some, but not many EHR systems that presently capture this data.  Of course, I would expect most are all able to be configured to capture it, but then when you add the measures for whether it was captured for patients, it gets a bit trickier.

The big mess is in the capture of social, psychological and behavioral data.  I don't doubt the value of this as specified in the rule, but it begins to become invasive with respect to patient privacy.  Not only will this involve a bunch of new data capture screens, but also requires enhanced security due to the more sensitive nature of some of this data.  It also begs the question of how much data SHOULD be required under the certification and incentive rules.

Adoption of the CDS Knowledge Artifact and Service standards is also going to be challenging. There's still a lot of work being done to clean up and harmonize the specifications.

Overall, I long for the day when a Certification rule adopts no standard that is still in its infancy. Granted, we have a long way to go before we get there, but we are still in that period of early growth where every day brings new changes.  At some point, I'd love to get this program to a point where the improvement is more evolutionary than revolutionary.  I'm not arguing the need for revolution, BTW, just wishing that we didn't need so much of it at once.

   -- Keith

P.S. There will be more when I've had a chance to read another hundred pages or so...

* Note that while I think C-CDA Release 2.0 is also going to be challenging, I haven't really analyzed all the details for that yet, since it is in the Care Coordination Section.


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