Lost amidst the intrigue and questions around the new MIPS and APM programs from CMS is the pressing issue of the very slow rollout of 2015 Edition certified EHRs and how this could impact meeting the deadlines imposed by these new CMS value payment programs.
The release of the 2015 Edition criteria is now the third major offering of criteria from the ONC (excluding the 2014 Edition Release 2 which was more of a minor release). Each launch has also coincided with a new program or new stage from CMS where clinicians and hospital had a “deadline” to begin using this new edition to qualify for their payment program.
2011 Edition launched in September 2010 to support Meaningful Use Stage 1, and ambulatory providers had to begin using this new edition no later than October 2012 (hospitals had to start 3 months prior).
2014 Edition launched in February 2013 to support Meaningful Use Stage 2, and ambulatory providers had to begin using this new edition no later than October 2014 (hospitals had to start 3 months prior).
2015 Edition launched in April 2016 to support Meaningful Use Stage 3 as well as MIPs, and clinicians and hospitals have to begin using this new edition no later than January 2018.
We are now at the 5-month mark from the launch of the 2015 Edition program as ONC-ACBs were approved to begin doing certification in April 2016. What is interesting and somewhat troubling is in comparing the pace of certified products at the same timeframe from the launch of the previous editions.
As of the end of August, there are only 11 total certifications from 3 different developers of Epic, Allscripts and ModuleMD/Carefluence. Compare that to previous editions in terms of number of certified products and developers at the same point in time (5 months into their launch).
The numbers listed above for 2011 Edition and 2014 Edition are based on data available through the ONC CHPL. It is difficult to get the exact number of unique products and developers as you have to factor out the listing of multiple version of the same product or the same product listed multiple times because of reseller agreements or rebranding. Still, these number are very good approximations and serve to accurately contrast each rollout.
Yes, there were approximately 250 certified products within 5 months of launching the ONC program. Most clinicians and even other developers would be hard pressed to name more than 50 EHR systems, but 2011 Edition eventually got well over 1000 unique certified products by the time all was done.
While the 2014 Edition pace was far below its 2011 Edition predecessor, it numbers were not bad, especially considering the time for testing had nearly tripled compared to 2011 Edition (2-3 days at least for 2014 Edition vs 1 day in 2011 Edition). Also, nearly all of the major EHR vendors (MEDITECH, McKesson, MEDHOST, athenahealth etc.) had some certification by then, and many vendors were participating in some form of testing at that time. By February 2014, one year from launch, there were over 400 unique products certified on 2014 Edition.
If you compare test dates in first 5 months of 2011 Edition (average 1 day) vs 2014 Edition (average 2.75 days) you get a much closer result of 254 test-dates resulting in certification (2011 Edition) vs 187 test-dates (2.75 x 68) resulting in certification (2014 Edition). It just illustrates the work of developers in the early launch of 2014 Edition was basically the same as in the early launch of 2011 Edition.
The pace of developers releasing 2015 Edition certified products is way below previous pace. Even considering 2015 Edition testing is almost certainly a 3-day test event and maybe even needing 4 days for main EHRs (i.e., the old “Complete EHR”) to complete, pace is 4 months behind what we saw with 2014 Edition.
Of course, there are other factors which are mitigating the slow rollout of 2015 Edition products. The lack of Final Rule for MIPS and APM has prevented ONC from creating test data for Meaningful Use/Advancing Care Information measures (315.g.1/g.2) as well as overall uncertainty of what exactly is required of providers for certified EHR technology and when they must have 2015 Edition. One of the most important test tools, Cypress, was only recently approved for the testing of CQMs and impacted roadmaps and development plans.
However, there is no denying developers are putting off starting their 2015 Edition testing. That is not necessarily a bad thing as many developers felt they rushed their work on 2014 Edition because of the tight deadlines and as a result did not make their products as usable and robust as they would have liked. Yet, policy makers, clinicians, and hospitals should take note of this as it is very likely many EHR systems, especially the smaller developers those targeting small practices, will be hard pressed to complete their certification by January 1, 2018 given the current pace.
What does that mean for developers? First and foremost, you are certainly not “behind” if you have not yet started working on 2015 Edition as the market is still slow to move on it. However, it is also reflective that 2015 Edition testing is simply more difficult than before. A very valid reason for the slow pace is that 2015 Edition test procedures and test tools have increased in complexity. It is why developers need to quickly begin moving into planning stages.
Because of its complication and the approach deadlines, guidance and insight can maximize efforts to increase time to market and reduce time spent in development. That is what Chart Lux does: we show you how to make sense of the challenging and complex of healthcare IT requirements. Contact us to find out more.