ONC 2015 Edition Certification Rule Synopsis

 

We wish we could say the same about the ONC Certification Rule. Whereas the CMS rule seems to be using MU Stage 3 to stabilize expectations, the ONC rule does the opposite and crams too much into the 2015 Edition Certification. To make matters worse, the rule isn't laid out clearly or logically, so it's hard to ascertain how all of the pieces fit together.

 

There are 68 individual certification requirements described in the ONC rule. It would be impossible to lay out all of the details here. The list of all of the requirements is here.

 

There are 36 of the 68 requirements that are required for meaningful use. ONC introduces the concept of the "Base EHR", which has the following 16 requirements. New requirements are marked with a *.

 

 • Demographics

 • Problem List

 • Medication List

 • Medication Allergy List

 • Smoking Status

 • Implantable Device List*

 • Clinical Decision Support

 • CPOE – medications

 • CPOE – laboratory

 • CPOE – diagnostic imaging

 • Transitions of Care

 • Application Access to Common Clinical Data Set*

 • Direct Project, Edge Protocol, and XDR/XDM

 • Direct Project

 • Clinical Quality Measures – record and export

 • Data Portability

 

But for meaningful use, CMS says that you need the base EHR, plus 20 more requirements:

 

 • Automated Measure Calculation

 • Automated Numerator Recording

 • Patient Health Information Capture*

 • Family Health History – pedigree

 • Family Health History

 • Transmission to Public Health Agencies – health surveys*

 • Transmission to Public Health Agencies – antimicrobial use and resistance reporting*

 • Transmission to Public Health Agencies – reportable condition reporting*

 • Drug-drug, Drug-allergy Interaction Checks for CPOE

 • Transmission to Cancer Registries

 • Transmission to Public Health Agencies – reportable laboratory tests and values/results

 • Transmission to Public Health Agencies – syndromic surveillance

 • Transmission to Immunization Registries

 • Secure Messaging

 • View, Download, and Transmit to 3rd Party

 • Drug-formulary and Preferred Drug List Checks

 • Electronic Prescribing

 • Clinical Information Reconciliation and Incorporation

 • Patient-specific Education Resources

 • Clinical Quality Measures – Report

 

So what are the additional 32 requirements if they're not required for meaningful use? It's the list below, arrayed in order of decreasing complexity as estimated by ONC.

 

 • Electronic Submission of Medical Documentation*

 • Accessibility Technology Compatibility*

 • Consolidated CDA Creation Performance*

 • Vital Signs, BMI and Growth Charts

 • Data Segmentation for Privacy (Federal substance abuse privacy law) – send*

 • Data Segmentation for Privacy (Federal substance abuse privacy law) – receive*

 • Quality Management System

 • Decision Support – knowledge artifact (send CDS interventions)*

 • Transmission of Laboratory Test Reports

 • Clinical Quality Measures – filter*

 • Incorporate Laboratory Tests and Values/Results

 • Safety-Enhanced Design

 • Care Plan (consolidated from multiple care plans)*

 • Social, Psychological, and Behavioral Data*

 • Decision Support – service (receive CDS interventions)*

 • Healthcare Provider Directory – query response*

 • Healthcare Provider Directory – query request*

 • Clinical Quality Measures – import and calculate

 • Accessibility-Centered Design*

 • Integrity

 • End-User Device Encryption

 • Emergency Access

 • Automatic Access Time-out

 • Amendments

 • Audit Report(s)

 • Auditable Events and Tamper-resistance

 • Authentication, Access Control, Authorization

 • SOAP Transport and Security Specification and XDR/XDR for Direct Messaging

 • Accounting of Disclosures

 • Image Results

 • Patient List Creation

 • Electronic Medication Administration Record

 

Buried within these 700+ pages of proposed federal regulations are many objectives, measures and requirements, as well as a lot of hopes, dreams and aspirations – what we would characterize as The Good, The Bad and The Ugly.