Certified EHR Technology: CEHRT Final Rule Enhances Value Proposition for Health IT Interoperability

21 million is the number of results returned by a recent Google search on the terms Health IT and interoperability. An observer of hotly debated healthcare topics could reasonably conclude that the results reflect millions of opinions about which protocols, standards, and networks are best suited to deliver clinical data in a way that maximizes health outcomes without inflating cost.

While there’s plenty of room to debate the relative merits of, for example, Direct Secure Messaging versus FHIR APIs, there is a growing consensus that interoperability is a hydra-headed problem that can only be solved by a combination of methods. The 2019 Quality Payment Program final rule, released on November 1st acknowledges this reality by making ONC 2015 certified EHR technology (CEHRT) a pre-requisite for incentive payments as of January 1, 2019.

CEHRT doesn’t resolve the interoperability debate but it empowers providers with a base toolkit of capabilities that can overcome fundamental interoperability issues around sending, receiving, and integrating patient information from external sources.  The Health IT standards that EHRs must incorporate to meet ONC’s Base EHR Definition – Direct Secure Messaging, FHIR APIs, and C-CDA – can rapidly enable interoperable workflow for care transitions, consultation notes, diagnostic imaging reports, discharge summaries, history and physical summaries, operative notes, procedure notes, progress notes, and more.

As 2019 approaches, there are a surprising number of EHRs and health IT platforms that are hold outs with respect to 2015 Certification.  The Quality Payment Program final rule monetizes interoperability with millions of dollars in incentive payments from CMS programs referencing ONC Certified Health IT.  With a dollar value firmly linked to 2015 Certification, it seems a matter of time before vendors take the plunge on their own initiative or are forced to do so by their users.

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