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The Good, the Bad, and the Ugly of 2015 Edition Certification

I have had the opportunity to work many different EHR systems in pursuing 2015 Edition certification. It has been a great experience and very eye opening on what challenges face developers. Some quick thoughts on the good, the bad, and the ugly of achieving 2015 Edition certification.


Self declaration testing does help. When ONC announced that nearly half of their criteria can be successfully tested via self-declaration they allowed developers to noticeably reduce their project timeline. The features still must be developed and do some internal QA verification, but the times to prepare for the ONC-ATL test date and the test event itself will be be removed. Also, there is just less pressure on tripping over a minor issue within the test (see the 2nd Bad point).

Solid guidance in CCG and test tool forums. An excellent addition by the ONC has been their certification companion guides (CCG) they offer beyond their test procedures. They have some excellent points, and I applaud them for making this resource and continuing to update it. Also, the contractors and staff who support the Google Group test tools forums do a great job of answering questions.


The turbulence of the test tools. While the staff is great on answering questions on the tools, they really have changed and modified the tools too much, especially with the ETT and C-CDA validation. Too often developers have found their EHR suddenly not working with the tools and their test date looming. I understand the need to to improve and update the tools as they are basically a mini-EHR product, but I wish the process was different.

The nuances and minor requirements. While the companion guides are wonderful, the fact that you need them reveals how difficult it is. There are some many minute details to capture and get right. 2015 Edition deceives you into thinking it is mostly the same as 2014 Edition requirements until you encounter the details of the proctor sheets. Nearly every developer who has started 2015 Edition testing will tell you it has taken far longer than they expected. Proper time for QA and mock testing is critical.


Automated Measure testing is wicked. The testing requirements for 315.g.2 automated measure is simply brutal. You have to track activities by NPI/TIN combination which means the same provider (NPI) working in multiple TINs within the same EHR instance and separating the activities per TIN. Except when we are dealing with transitive measures (although ONC recently introduced some flexibility there). It just very complicated, and I personally don’t think it necessary, or at least should have more optionality, but it is what it is. And it is ugly (and hard and necessary).

Usability and workflow challenges. I know ONC and the industry is pushing usability and burden reduction, and I know it is important for the developers. Still, trying to put in all the features with all the nuanced requirements and streamline it so it is “MIPS friendly” is not easy. As mentioned above, 2015 Edition testing simply lasts longer than you had prepared for which means you are rushed to finally complete it which means less time for the hard decisions of design and UX layout to maximize the workflow and operations.

Still, these tasks, including the bad and ugly, can be done. I’ll be glad to talk with developers or clinicians on how to do this, improve and save on the 2015 Edition certification project, and make a quality EHR system and deployment.

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