The American Medical Informatics Association is urging the Office of the National Coordinator for Health IT to develop deeper electronic health record reporting requirements than those mandated by the 21st Century Cures Act.
Signed into law in December 2016, the Cures Act calls for a transparent process to develop criteria as part of an “EHR Reporting Program” for certified health IT. The reporting program was meant as a way to engage stakeholders and gather information about EHR usability, interoperability, and security to help providers better choose EHR products.
However, AMIA believes the EHR reporting program should bring transparency to how certified EHRs perform in production environments with live patient data, the association noted in a comment letter to regulators.
“ONC should develop an EHR reporting program that more closely approximates a post-implementation surveillance ecosystem, not a government-sponsored ‘consumer reports,’” according to AMIA. “Such an ecosystem would illuminate certified EHR performance used in production and would generate product performance data automatically without users having to submit reporting criteria.”
Specifically, the association points to ONC’s existing surveillance and oversight program for certified EHRs—that is just coming into existence—that AMIA contends could be leveraged for the EHR reporting program.
In addition, the group suggests that ONC look at the Food and Drug Administration’s Digital Health Software Precertification Program as an example of a federal program that seeks to use real-world production data.
“This concept of real-world production data is a reality in most, if not all, certified electronic health records,” states AMIA’s letter to ONC. “For example, one well-known developer has the capacity to report how frequently a summary of care record failed to send for an ordered care transition. In this example, users can see if the failure occurred in the ordering workflow, if the failure occurred in transit, and whether the transaction was received and acknowledged by the recipient system.”
Another example offered by AMIA is how EHR developers calculate Provider Efficiency Profiles, which provide clinician-level data about workload, system usage, specific number of tools adapted, amount of time in certain activities, as well as time spent during specific hours of the day.
The complete AMIA comment letter to ONC is available here.