Health Level Seven (HL7) International sent a letter to the Office of the National Coordinator (ONC) for Health Information Technology regarding the proposed rule on the certification programs for health information technology. The two primary comments are as follows:
- HL7 has produced the Electronic Health Record System Functional Model (EHR-S FM), which was done at the urging of CMS and HHS and has been used by CCHIT in past certification criteria. “HL7 strongly recommends that ONC continue to include functional requirements as part of the certification program.”
- HL7 recommends that other systems other than EHRs be certified. HL7 has developed the PHR System Functional Model (PHR-S FM) which can be used as part of the certification process, just as the EHR-S FM is. HL7 goes on to recommend that EHR systems across the spectrum of care be certified as well, and HL7 has profiles for “…Emergency Department, Long Term and Post Acute Care, Behavioral Health, and Child Health…”
Read the complete HL7 Letter on the proposed certification programs (PDF).
A few other comments on the proposed certification programs have been submitted. American Health Information Management Association (AHIMA ) and the Medical Group Management Association (MGMA) have submitted letters to the ONC. iHealthBeat has an article – Groups Comment on Proposed Certification Rule for EHR Systems – which highlights the key points of their comments. Both of these organizations comment on already certified EHRs: “allow CCHIT-certified products to remain certified until temporary certification entities are operational and able to re-certify the products” (AHIMA position) and “recognize EHR products certified by CCHIT in 2008 or later as meeting the requirements of stage 1 of the EHR incentive program” (MGMA position).
So, a quick summary of comments emerging on the proposed EHR certification programs – one coming from a healthcare standards organization and the others coming from healthcare trade associations. There is a definite difference in comment approach between the two types of organizations, and there will likely be more comments coming from others.
One thing is certain about HITECH / Meaningful Use today – it has created opportunity for many, many organizations to comment on its various components.
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