The electronic health record (EHR) standard has been receiving widespread attention since the spring of 2003, when the Centers for Medicare and Medicaid Services (CMS) and the Department of Health and Human Services asked the Institute of Medicine for guidance on the key care delivery-related capabilities of an HER and Health Level 7 to subsequently develop a functional model. Now that the second version of the EHR draft standard has been approved this past April, whats next?
First, it is important to remember that this is a draft standard for trial use (DSTU)a version good enough to move the initiative forward, but with many opportunities to enhance the functional outline over the two-year period. Existing functions may be continuously refined, others may be deleted, and new functions may be added.
The functional outline was designed to be practical yet visionary. It contains functions that are essential to caregivers and can be implemented now. But it also contains functions that EHR systems have long promised by that cannot be delivered until the technology is ready to implement them. Given both situations, no EHR system vendor will be fully, or even highly, compliant with the draft standard whenever it is approved.
According to industry expert Margaret K. Amatayakul, MBA, RHIA, CHPS, FHIMSS, in her new book
Electronic Health Record: A Practical Guide for Professionals and Organizations, the electronic health record is not a single product. It may not even be a group of products. Rather, the EHR is the end result of integrating all applications and applying appropriate technology and analytical tools to create information that contributes to the improvement of the healthcare delivery system.
The two-year DSTU period is a time when:
- Providers can better understand what an EHR is, how it will benefit them, and what individual functions are most important to them.
- Vendors can better understand both the standard and their customers needs, as well as set product direction.
How do these two points translate into reasonable client-vendor interaction? At the beginning of an EHR system selection process, providers can use the functional outline as a guideline for the requests for proposals. However, it is important to distinguish what is identified as a business or functional requirement in a request for proposal is not the same as saying that a function is required simply because it is in the standard.
For example, a provider may focus on the true functional requirement to receive a notification of a specific virus or disease outbreak from a public health agency on a real-time basis. He or she could fairly use this function to communicate to a vendor about how they would like that function to perform. It would even be fair for the provider to compare vendors against this and other functions. But it may be unfair to malign the vendor when the reference within the standard suggests this capability to be essential but it cannot be implemented electronically until some time in the future or when there are no products that currently contain this function.
By the same token, this is also an opportunity for vendors to begin retooling their products to communicate to their customers when their products will become increasingly compliant with the standard. It will be easier to explain to their customers that they are using this time, while the standard is still a draft, to prepare for the eventual fully accredited standard.
It is expected that at the end of the two years the draft should be of sufficient quality that it can then be balloted as a fully accredited standard. Even then, there is still some flexibility. A revised DSTU can be filed at the end of the two-year period and another enhancement cycle could conceivably go into effect. Certainly, though, the industry will not want to, and cannot, wait that long for an EHR standard to be approved.
The DSTU offers great flexibility in getting the standard out for vendors to begin testing their products before the fully accredited standard is approved. It will also allow CMS to conduct its long-awaited demonstration projects testing its proposal to provide differential payment to clinicians who use an EHR to improve quality and effectiveness of care.
It is important that the EHR standard progress as quickly as possible, moving the industry closer to reaping its benefits, yet still keeping the opportunity to enhance it over time.
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