CCHIT Offers Public Comment On Standards And Criteria IFR

March 16, 2010

CHICAGO – March 12, 2010 – The Certification Commission for Health Information Technology (CCHIT®) today submitted its public comments on the Interim Final Rule (IFR) entitled “Health Information Technology: Initial Set of Standards, Implementation Specifics, and Certification Criteria for Electronic Health Record Technology” to the Office of the National Coordinator (ONC). 

“We congratulate ONC on development of the IFR, but we believe the criteria and standards need refinement in order to drive an achievable step forward in the meaningful use of EHRs,” said Mark Leavitt, M.D., Ph.D., chair of the Certification Commission, adding that the Commission is “concerned about the possibility of an unintended deceleration in the pace of EHR adoption.”

The comments highlight three broad concerns about the IFR requirements:

  • Under the IFR, the scope of a ‘Complete EHR’ inappropriately includes administrative and billing functions, diverting funds and effort into unnecessary certifications of already-installed  billing systems for every doctor and hospital seeking the EHR incentives.
  • Certain criteria and standards in the IFR may represent a step backwards in progress toward EHR interoperability, by dropping standards that were already federally-recognized and widely adopted, while other criteria demand an unrealistic leap forward.
  • Some IFR criteria define required functions of an EHR too microscopically, adding unnecessary costs and complexity, and creating barriers to innovation.

The Commission also commented on the regulatory impact analysis required as part of the rule making process.  While the IFR concludes that the new rules would not impact a significant number of small businesses, the Commission supplied data and analysis indicating the impact would be very substantial.

A copy of the comments, including a more detailed analysis is available at http://cchit.org.

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