In March 2010, HHS released the health IT certification program NPRM or Notice of Proposed Rule Making. Visit the HHS site to learn more about the NPRM for certification. The certification program is a result of HITECH and Meaningful Use. As part of the NPRM process, several organizations have released comments about the proposed rules for certifying health IT. Three to take note of include:
- Health Level Seven (HL7) International – PDF statement
- American Health Information Management Association (AHIMA) – PDF statement
- Markle Connecting for Health – PDF statement
Each statement offers interesting perspectives. One of the differences between these three is on what to certify. While AHIMA and HL7 urge incorporating more into the certification program, primarily Personal Health Records (PHR) and Health Information Exchanges (HIE), Markle is hesitant to put it all under a certification program. Their perspective:
“Regardless of the technology in question, the approach to certification should be limited to the minimum needed to enable providers to meet the Meaningful Use objectives, interoperability and existing privacy and security requirements. The cost of expanding the certification program should be carefully weighed against the benefits. However, HHS should allow PHRs or HIEs that wish to be qualified as EHR modules for purposes of helping providers and hospitals achieve Meaningful Use. We consider PHRs and HIEs separately below.”
From my perspective, two key points from their statement:
- Keep certification focused on what is needed for providers to meet Meaningful Use and associated requirements
- There is a cost to expanding the program – be careful
Good advice. There is enough to be done, so stay focused on what is necessary to meet Meaningful Use. There are many programs being launched already as part of HITECH, so be careful to not over-extend and over-program (see point 1).
Connecting for Health does a good job with their comments on the proposed certification program. It is worth reading in detail their recommendations on four key areas of the proposed health IT certification program:
- HHS should create clear, standard language about the purpose and goals of its certification program, and its limitations in addressing important public policy questions raised by the adoption and use of health IT.
- HHS should clarify the rules by which EHR modules may be exempt from testing against all privacy and security certification criteria.
- Except for the specific circumstances in which such services are being used to help health care providers and hospitals qualify for Meaningful Use incentives under ARRA, HHS should limit the scope of extending the current certification program to other forms of health IT such as electronic personal health records (PHRs) or health information exchanges (HIEs).
- HHS should clarify the type and scope of modifications that would require a 65 product to be recertified.
If you have the time to review only one of the three organization’s comments, read Markle’s Connecting for Health’s statement. It is more meaningful and insightful.
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