Conditions of Certification
In a previous blog, we mentioned that there’s a six month window for any “Certified API Developer” to “publish all terms and conditions for its certified API technology, including any fees, restrictions, limitations, obligations, registration process requirements or other similar requirements.” It is important to note that this applies to any API certified to 170.315(g)(7) through (9) and is independent of, and separate from, the requirement for APIs to conform to the FHIR standard (see previous blog). So these publication requirements precede any of the new FHIR requirements.
Transparency: Developers must provide publicly accessible documentation for those wishing to interact with their certified API.
Fees: Fees are restricted but allowed to cover development, deployment, upgrade and usage of the API. EHR developers can also charge for “value-added services” over and above the basic certified API functionality.
Openness: Developers “must grant API Information Sources the independent ability to permit API Users to interact with the certified API technology deployed by the API Information Source”. Also, API Information Sources and API Users must be allowed full access and ability to provide products and services that leverage the API.
Maintenance of Certification
As a certified EHR developer, there are new ongoing tasks you’ll need to follow. Attestations must be submitted every 6 months, starting April 1, 2021, with a 30-day window for submission.
ONC has introduced an interesting new concept and associated requirement: “Real world testing” and it is required for 170.315(b), (c)(1-3), (e)(1), (f), (g)(7-10) and (h). Real world test (RWT) plans must be developed and submitted to your ONC-ACB in order to maintain certification.
RWT plans are intended to demonstrate that CEHRT meets intended use cases in a production context.