Premier responded to the Office of the National Coordinator for Health IT (ONC)’s request for comments on the proposed measures for HIT developers as part of the Electronic Health Record (EHR) Reporting that was established in the 21st Century Cures Act.
Premier focused its comments on the need for healthcare providers to have reliable, robust, and transparent information about EHRs’ usability, functions and interoperability. Premier urged ONC to:
- Explicitly identify how its proposed measures address usability, security, and user-centered design;
- Establish a stronger focus on patient safety-related usability, EHR training and transparency on EHR vendors’ cybersecurity practices, as well as cost transparency;
- Adapt the Safety Assurance Factors for EHR Resilience (SAFER) Guides for use by EHR vendors and implement certification requirements for EHR vendors to attest to completing an assessment of their technology and product and to publicly report that information as part of the EHR Reporting Program;
- Continue to implement more robust conditions and maintenance of certification, testing and surveillance processes to ensure that EHR vendors demonstrate their systems’/platforms’ interoperability; and
- Provide transparent information that reveals data about product performance enabling a side-by-side comparison across EHR products and measures to ensure next generation product improvements are based on real-world data.
Premier also offered recommendations on specific proposed measures and domains for patient access, public information exchange, clinical care information and standards adoption.