There’s an important deadline November 2nd *: Compliance Requirements start for Conditions of Certification:
Assurances: Health IT developers must provide assurances that they will not engage in prohibited Information Blocking (see below)
APIs: We covered API Conditions of Certification in a previous blog: Basically, you need to provide complete documentation, reasonable open access, and publication of fees for your existing API.
* ONC enforcement discretion offers a 3-month grace period until February 1st.
EHR vendors (health IT developers) are prohibited from blocking access, exchange, or use of Electronic Health Information (EHI). Eventually (36 months after publication), this will extend to include the full HIPAA definition of ePHI. For the November deadline, Information Blocking is limited to US Core Data for Interoperability Version 1 (USCDIv1) and that’s good news for vendors because USCDIv1 is basically the familiar Common Clinical Dataset with a couple of new Data Classes and Data Elements (noted in the table, below):
Think of USCDI as a superset of the CCDS. According to ONC, it “sets a foundation for broader sharing of electronic health information to support patient care”. ONC views the additional Vital Signs as important for pediatric care and Previous Address can be valuable for patient matching.
For those of you certified for 2015 CEHRT, you may be under the impression that you have 24 months after the Final Rule publication date to certify on the new and modified USCDIv1-related criteria:
C-CDA: 170.315(b)(1), (b)(2), (b)(9), (e)(1), and (g)(6)
FHIR: (g)(8) and (g)(9)
Well technically, that’s true. But you’ll need a mechanism to output the USCDIv1 data elements for the November deadline and the only two reasonable ways to do this are via FHIR API and C-CDA. So, although you don’t need to re-certify the USCDI-related criteria right now, you’ll want to have the USCDI functionality in place for the November deadline.
As your strategic partner, DHIT strives to stay ahead of regulatory deadlines. We have already undergone ONC Testing for (b)(10) EHI Export to ensure you are covered for USCDIv1 data export.