Premier Comments on ONC’s Request for Information on the EHR Reporting Program

Premier submitted comments in response to the Office of the National Coordinator for Health Information Technology (ONC) RFI on the EHR Reporting Program. The 21st Century Cures Act requires HHS to establish an EHR Reporting Program for health IT developers to ensure that comparative information is publicly available on certified health IT products used by hospitals and other healthcare providers.

In its response to the RFI, Premier urged the ONC to:

• Focus first on obtaining vendor data about certified EHRs in ambulatory and inpatient settings and those that are used to fulfill CMS and other federal reporting and administrative programs;
• Consider an incremental implementation of the EHR Reporting Program, including pilot testing (across various provider settings and users) of proposed criteria, broad information dissemination and ongoing stakeholder education;
• Integrate and align the EHR Reporting Program requirements within the Health IT Certification Program;
• Implement more robust conditions and maintenance of certification, testing and surveillance processes to ensure that EHR vendors demonstrate and attest to their systems’/platforms’ interoperability and conformance to standards; and
• Not apply any new or additional provider reporting or data collection requirements as part of the EHR Reporting Program. Rather, Premier urges ONC to require EHR vendors to demonstrate interoperability, usability, security and their platforms’ conformance to standards as part of a more robust certification, testing and surveillance programs.