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Certification / Adoption Workgroup. Larry Wolf. May 13th, 2014. Agenda. Update from May HITPC Meeting Update from Certification Hearing Proposed LTPAC Patient Assessment Recommendation Next Steps: LTPAC / BH Voluntary Certification Blog Listening Session – Thursday, 05/22/2014.

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Certification / Adoption Workgroup

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Certification / Adoption Workgroup

Larry Wolf

May 13th, 2014


  • Update from May HITPC Meeting

  • Update from Certification Hearing

  • Proposed LTPAC Patient Assessment Recommendation

  • Next Steps:

    • LTPAC / BH Voluntary Certification Blog

    • Listening Session – Thursday, 05/22/2014


Update from May HITPC

  • TOC & Privacy Recommendations Approved by HITPC w/ the following clarifications:

    • Alignment with MU: TOC certification criteria and standards should align with ONC’s Meaningful Use criteria and standards to ensure interoperability across systems and to encourage exchange.

    • Updated with MU: Starting with the 2014 Edition of CEHRT, criteria and standards for other settings should be updated when MU criteria and standards are updated.

  • Data Segmentation/Consent Management

    • Provider Workflow: HITPC requested that the Privacy & Security Tiger Team (P&S TT) conduct additional outreach to stakeholders to determine the workflow impact of data segmentation and consent management of documents. The P&S TT will engage in this outreach in May

    • Definition of Disclosure: P&S TT also will work with SAMHSA to determine the definition of disclosure used for purposes of 42 CFR part 2

    • Report Back to HITPC: P&S TT anticipates reporting back to HITPC in June with updated recommendations

Update from May HITPC

HITPC Feedback on Draft Quality Measurement Recommendations for LTPAC / BH Voluntary Certification

  • Noted that the proposed behavioral health quality measures are process focused, and should be more focused on outcomes.

  • Consider how data already collected from LTPAC/BH providers (e.g., by CMS) could provide a foundation for quality measurement in the setting

  • Interested in additional vendor feedback on the proposed quality measure recommendations

  • Consider international examples of ways to integrate behavioral health, maternal health, social care programs, etc. to render a holistic view of the patient

    2015 NPRM Feedback

  • HITPC to provide ONC with 2015 NPRM discussion ‘sentiments’

    • Certification should be ‘lean and mean’

    • Balance between maturity of standards and infrastructure needed to support policy (e.g., Meaningful Use, Advanced Care Models)

Feedback from Certification Hearing

  • The certification process is overwhelming for some (timeframes, complexity)

  • Certification of immature criteria/standards are concerning

  • The certification schedule involves tight timelines and cycles that vendors must work within

  • Certification regulations lack clarity

  • Feedback mechanisms beyond the NPRM process are needed

  • Certification can stifle innovation

Certification Hearing Outcomes

Key Points:

  • ONC should organize a Certification Kaizen

    • Need for active collaboration with all stakeholders, including CMS

    • Kaizen process is more effective than responding to NPRMs

  • Certification efforts should focus on interoperability, privacy and security, and quality measures

Voluntary Certification for LTPAC and BH

Proposed LTPAC Setting Specific Recommendation

LTPAC Patient Assessments

Policy Opportunity:  

  • Alignment among federal programs around data and standards

  • Patient assessments can be key drivers of interoperability

    • Previous standards mapping work has been done (e.g., mapping assessment content to vocabulary standards, CCDA)

  • Responsive to certification hearing concerns regarding the lack of interoperability

LTPAC Setting Specific Recommendations

Interoperability of LTPAC Patient Assessment Data

  • NEWSupport the ability to create, maintain, and transmit (in accordance with CMS requirements) assessment instruments and data sets for LTPAC in, for example, MDS 3.0 (Nursing Homes), OASIC-C (Home Health), IRF-PAI (Inpatient Rehabilitation Facility), CARE subset (for Long Term Care Hospital), and a Hospice Item Set.

  • NEW Support the use of accepted vocabulary standards to enable the reuse of assessment data for:

    • various clinical purposes; and

    • administrative purposes.

  • NEW Support the ability of the provider or a designated third party to create and exchange interoperable LTPAC Assessment Summary CDA documents.


  • Harmonization of federal content and format for patient assessments with ONC specified EHR standards (e.g. consistent standards on demographics).

  • Make the data element library publically available and link content to nationally accepted standards.

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