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MU Compliance Announcement Sparks Concern, Confusion

Scott Mace, for HealthLeaders Media, December 9, 2013

According to CMS' announcement, "This approach is designed to provide public input on policy proposals, enable our certification processes to more quickly adapt to include newer industry standards that can lead to greater interoperability, and add more predictability for EHR technology developers. We also anticipate that this new approach would spread out over a longer time period the certification requirements to which EHR technology developers have previously had to react."

The first step under this new approach would be to publish a proposed rule for a 2015 Edition of certification criteria.

"We intend for the 2015 Edition certification criteria to improve on the 2014 Edition certification criteria in several ways," the CMS announcement states. "We expect the 2015 Edition would be responsive to stakeholder feedback; would address issues found in the 2014 Edition; and would reference updated standards and implementation guides that we expect would continue momentum toward greater interoperability.

CMS also stated that it expects to propose that the 2015 Edition would be voluntary in the sense that providers participating in the EHR Incentive Programs would not have to upgrade to 2015 Edition EHR technology, and no EHR technology developer who has certified its EHR technology to the 2014 Edition would need to recertify its products. CMS' intention would be for the 2014 Edition to remain the baseline certification criteria edition for meeting the Certified EHR Technology definition.

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1 comments on "MU Compliance Announcement Sparks Concern, Confusion"


Frank Poggio (12/9/2013 at 10:05 AM)
From a vendor perspective 2015 test criteria is a wolf in sheep's clothing. In my experience having worked through many 2014 tests with clients - the criteria under 2014 became considerably more complex and extensive as each month passed, test criteria were revised almost on a monthly basis. For example the test for Safety Enhanced Design (170.114g3) started out requesting a simple description of your design/development process, to now submitting detailed test scenarios per NISTIR 7742 standards. The DVT test now requires WCAG 2.0 evaluations, but did not in the early gong. This growing complexity is one reason why far less vendors have passed 2014 than 2011. From a vendor perspective, the net result is if you wait for the new set of 2015 test criteria those tests will be even more difficult. My advice, don't wait too long. Remember in the healthcare world regulations only grow...never shrink!