Certification / Adoption Workgroup

1. Certification / Adoption Workgroup Larry Wolf, chair Marc Probst, co-chair March 19, 2014

2. Agenda • Feedback from March 11th HITPC • Preparation for commenting on the 2015 NPRM

3. HITPC Feedback on LTPAC/BH Certification Charge • Certification can improve interoperability and patient care: • Provides a roadmap for standards adoption • Improve care alignment with other care providers • Increases provider confidence in technology and systems • Core concepts should be supported by recommendations: • Certification should focus on care coordination, transition of care, standardization of vocabulary • Certification needs to be modular enough to be affordable • BH specific comments: • Certification criteria for the ALL provider and Setting Specific categories should align with SAMHSA initiatives • Concern: Many EHR systems do not support BH provider needs • Other comments: • Need to ensure DSM decision logic is not lost in standards mapping • Commendation for modular approach, given the range of provider types • Consideration for employer information needs (e.g., EAP) • Consideration for other settings ( prison, jail, pharmacy) • Consider expanding recommendations beyond the medical model of care (e.g., social determinants of health) • Data availability is important to payers, providers and public health community

4. Next Steps from HITPC Incremental updates, report back and timeline extension More public input on recommendations needed New format for review of recommendation 3

5. DRAFT Work Plan Bolded items are HITPC meetings

6. Listening Session Topics • Comments on criteria within the certification capability categories: • ALL Providers • LTPAC/BH Setting Specific Categories • SOME Provider Categories • Modular Format (Is the modular format helpful in addressing the needs of the diverse provider types?) • Level of effort required for providers to implement/maintain the proposed certification criteria (workflow? technical support needs?) • Development effort for vendors to adopt and incorporate the proposed certification criteria • Appropriateness: Do the proposed certification criteria address the needs of the LTPAC/BH setting priorities?  What is missing? • Are the standards associated with the proposed certification criteria mature?

7. Commenting on the 2015 NPRM

8. The Subject Matter and Deadline What are we commenting on? Notice of proposed rulemaking: Voluntary 2015 Edition Electronic Health Record (EHR) Certification Criteria; Interoperability Updates and Regulatory Improvements (79 FR 10880). By When? The public comment period is open through April 28, 2014 but you’ll have a little more time (May 6th). 

9. Public Comment Template & Materials How are we commenting? • Public Comment Template • Submission:http://www.regulations.gov/#!documentDetail;D=HHS_FRDOC_0001-0532 Materials Checklist • 2015 Edition Proposed Rule (Federal Register Version) • Public Comment Template

10. Focus Areas for NPRM Comments • Incremental rulemaking (not tied to Meaningful Use) • Policy/program alignment & leveraging the ONC HIT Certification Program • 2015 Edition proposals • Discontinuation of the Complete EHR definition • Non-MU EHR Technology Certification • “Certification Packages” for EHR Modules • ONC Certification Mark • Other topics to be determined • 2017 Edition requests for comment • Additional patient data collection • Certification of Other Types of HIT and for Specific Types of Health Care Settings • Blue Button + • Other topics to be determined

11. We Need Volunteers  Lead Member(s) for Each Meeting • Expectations of Lead Member(s) • Provide the workgroup with materials, discussion points, and thoughts before the scheduled meeting (at least the day before) • Develop slides with support from ONC staff • Lead the discussion on the certification criterion/criteria or topic(s) • Hit the “big picture” issues, policies, and implications • Get into the weeds on standards and implementation • Keep us on schedule • Volunteer or be Volunteered! • To volunteer, contact at ONC

12. ONC Answers the Why

13. Why Incremental Rulemaking? • Less change between editions of certification criteria • Makes rulemaking more nimble, better able to keep up with industry updates • Provides ample opportunity for public comment and earlier visibility into potential policy directions

14. Some Reasons for a 2015 Edition • Commitment to see continued incremental progress toward greater interoperability for providers, individuals, and their families. • February 2012 was last time ONC proposed updated standards and implementation guides for certification. • The rulemaking gives HIT developers earlier and clearer “standards policy” direction. • This rulemaking includes proposals ONC is ready to make to improve already existing certification criteria. • Better positions HIT developers to respond to our near future 2017 Edition rulemaking, which we will publish jointly with CMS’ MU Stage 3 rulemaking. • Gap certification between the 2014 Edition and 2015 Edition and then between the 2014/2015 Editions and 2017 Edition could significantly expedite certifications and reduce regulatory burden. • Certification beyond Meaningful Use

15. The future: 3-year ONC Rulemaking Roadmap(milestones reflect best guestimates) CY 2014 CY 2015 CY 2016 Q1 Q1 Q1 Q2 Q3 Q4 Q2 Q3 Q4 Q2 Q3 Q4 MU2 EP Start Date 2015Ed NPRM 2015Ed Final Public Comment 2017Ed Final & MU3 Final 2017Ed NPRM & MU3 NPRM Public Comment 2018Ed Final 2018Ed NPRM Announced AnticipatedMU3 EH Start Date Public Comment