Got To Get It Done
I have had several discussions recently asking "why aren't more developers certifying for 2015 Edition" and I thought I would explore this subject and give some reasons why developers should stop waiting and start on 2015 Edition work.
I have written multiple times about the slow rollout of 2015 Edition certified products so I don't find the current situation surprising. In fact, I think there are two key reasons for this.
1. The CMS habit of changing requirements. Regulatory requirements are always tough to decipher (which is why you need a consultant ;) but CMS has made this situation even more challenging with their shifting timelines, and it is just not starting with 2015 Edition or MIPS. The performance periods for Meaningful Use were regularly shortened down to 90 days each year since at least CY 2014 even when CMS previously indicated they would be at a full calendar year. We have seen the "deadline" for a new ONC certification edition be postponed a few times, most recently with 2015 Edition moving from CY 2018 to CY 2019. Of course, you have a completely new program in MIPS getting started and then a name change ("Meaningful Use" to "Promoting Interoperability") thrown in as well.
I have spoke to several developers who ask me "do you think CMS will delay it again?" I don't think that is the case, but I understand why they ask. This leads to a hesitancy to start working on something new and time consuming like 2015 Edition.
2. Deceptive difficulty of 2015 Edition. This impacts the delay in two ways. First, 2015 Edition looks initially quite similiar to 2014 Edition which leads developers to think "we can get this done in 6 months" and push off its start to the next quarter or so. Many of the criteria are the same and seem rather easy. However, the other side of this, as they dig into 2015 Edition they begin to see the significant challenges of several of the criteria and their test tool requirements. The task suddenly looks much more daunting that they first anticipated which leads to more unintended delays.
Given that, why should developers start now on their 2015 Edition project planning and developer? Three reasons:
1. October gets here sooner than you think. For both MIPS and Promoting Interoperability (former EHR Incentive Program), the new deadline is October 2019 in terms of time left in CY 2019 for a 90-consecutive day performance period. If October 2019 is basically the absolutely dealine for eligible providers and eligible clinicians to start using a 2015 Edition for their 90 day performance period, you have to work backwards and think through all the steps necessary to get there. There is the development and project management to launch this version. There is the testing and certification with the ONC-ATL/ACB. There is the go-live date to push to customers and then get it deployed. Finally, you have training and support with customers for them to be comfortable with the new version.
If you have not started now on the initial project planning for development and certification, it is almost too late. There is so much to do to get to the point your customer can actually attest with a 2015 Edition certified solution.
2. Certification is not going away. While CMS's delays have been frustrating, they have never really stepped away from ultimately requiring 2015 Edition CEHRT. I think some developers secretly hope that CMS will push back 2015 Edition into CY 2020, but if CMS wanted to do that, they would have stated that in their recent IPPS NPRM. On the contrary, in that proposed rule, they explicitly stated they do not want to do this. As noted above, CMS has already delayed 2015 Edition once, but with the majority of the large EHR developers certified, they don't have the same incentive to do that again.
3. More is coming. On the HITAC meeting this month, ONC was asked about timing of new certification Edition. As you would expect, they were pretty tight lipped, but they definitely implied they plan on staying with 2015 Edition for now, at least in terms of not issuing a new 20XX Edition. However, it is clear they plan to build from it. Their next ruling, planned to be released as an NPRM in September, will clarify requirements around information blocking and interoperability. CMS continues to make references to utilize the API features described in 2015 Edition in other programs.
For developers that wait now, they run the risk of getting "lapped" on new regulations building on top of 2015 Edition. The reality is that ONC requirements are essentially de facto industry requirements for EHR and health IT systems. As CMS expands the definition of eligible clinicans, more providers and their developers will be affected.
Sometimes, you just have to take the medicine. If you have not started on 2015 Edition work, you need to start now. If it looks daunting, that is why Chart Lux Consulting is here. Reach out to Chart Lux and let's see how we can help.
