In April 2016, ONC-ACBs opened their doors for 2015 Edition certification. We are now nearing the one year mark, and it is a good time to take stock at how certification is proceeding and what types of products are getting certified.
As we noted last year, the launch was far slower than with 2011 Edition and 2014 Edition, but it was assumed things would pick up, especially with the release of the MIPS rule. Yet, the pace of actual certifications has remained significantly behind. It is striking how few certifications have been achieved compared to the previous Editions.
2011 Edition launched in September 2010 and within the first year had over 700 products certified.
2014 Edition launched in February 2013 and within the first year had nearly 300 products certified.
2015 Edition launched in April 2016 and within the first year (technically 11 1/2 months) has 56 products certified.
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 numbers are very good approximations and serve to accurately contrast each rollout.
These numbers can be explained by some factors. First, 2011 Edition was relatively easy and offered really no major advancements compared to the typical health IT system. It was more of a confirmation of existing functionality than adding a significant number of new requirements. Thus, developers could get certified almost as fast as they could sign-up.
2014 Edition was much more difficult with more advancements. Still, it came with a strong deadline of starting Stage 2, which required 2014 Edition, in a short time period after rolling out the ONC requirements. Developers had a strong incentive and clear path to test and be certified soon.
2015 Edition comes as MACRA was being rolled out and changing the landscape of health IT. This introduced significant uncertainty into the minds of both developers and clinicians. Changing of an presidential administration, specially one which is focused on change, certainly does not add to the confidence. On top of that, there were 2015 Edition test procedures and test tools not ready at the time of launch. This month we finally have our last test procedure (315.f.6 – Electronic Case Reporting) ready for review.
It should be noted that the low number of certifications does not necessarily mean developers are not testing. Many are signing up and testing now with ONC-ATLs, but achieving certification has been undeniably slow.
Beyond the numbers, it is interesting to see what kind of products have been certified. Here is a general breakdown of the types of health IT systems certified in 2015 Edition:
* Note – one certified product does both CQM and public health and is counted in both categories.
It noticeable how many CQM/analytics systems have been certified compared to the rest of the health IT products. It reflects how quality reporting has become so much more important in the MIPS world, with quality metrics representing 60% of your MIPS Composite Score in CY 2017 which impacts your payment adjustment. Also, CQM requirements for these analytic systems are not too different than in 2014 Edition. While many standalone EHRs find the QRDA import requirement of 315.c.2 difficult, this is standard functionality for CQM-focused systems.
It is also noteworthy that none of the certified products are yet certified in the automated measure criteria (315.g.1 or g.2). That test procedure only recently came out and has undergone some updates. Frankly, I believe it is more complex than is necessary which is causing some developers challenges in implementing.
Given the current status of certifications, it is hard to believe CMS will keep its current January 1, 2018 deadline for starting Stage 3 in the Meaningful Use Program with 2015 Edition CEHRT. I expect they will move to a 90 day reporting period for CY 2018 to align with the MIPS program to allow more time for adoption.
Regardless, there is still time to develop and implement 2015 Edition requirements. Because of its complication and the approach deadlines, guidance and insight into 2015 Edition 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.