Dr. John Halamka proposes alternate IT certification plan

In his perfect world, John Halamka, MD, CIO of Boston-based Beth Israel Deaconess Medical Center would reduce or eliminate the 2015 EHR Certification Rule and instead require just five elements for health IT certification.

He wrote in a post on "The Health Care Blog" that the technical requirements of the Medicare Access and CHIP Reauthorization Act are overly restrictive and place a significant burden on developers.

While MACRA intends to provide flexibility for providers by offering them a choice of metrics to meet, it means developers have to design products meeting every single standard. "For vendors, every 'OR' means an 'AND' — developers must implement everything in the rule because some stakeholder will demand every transaction in the regulation," Dr. Halamka wrote. "There was little curation in the rule and most of the HIT Standards Committee recommendations to limit scope were ignored."

But that doesn't mean he thinks MACRA should be scrapped altogether. Dr. Halamka wrote the rule is overly complex, but it gets at the right idea in creating a set of outcomes and enabling clinicians to choose measures and process improvements that are relevant to their practice.

"However, the entire HIT ecosystem is begging CMS to realize that the 2015 Certification Rule is mostly burden without benefit," Dr. Halamka wrote.

So, if he were writing the rules, Dr. Halamka said there are just five elements he would require to certify an IT product.

1. Using certain authentication standards to demonstrate an organization is a trusted exchange partner.

2. Using a FHIR-based query to request electronic data.

3. Using a URL to send data to an endpoint, called a RESTful approach.

4. Using a FHIR-based query to request a full listing of a patient's record locations.

5. Using a FHIR-based query to actually exchange records.

Dr. Halamka wrote that limiting certification to these five key elements would ensure the interoperability healthcare stakeholders desire and developers can provide.

"We can be thoughtful and incremental about addressing regulatory zeal," Dr. Halamka wrote. "If Brexit taught us anything, it's that over regulation leads to a demand for relief."

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