ONC: Include appropriateness criteria in CEHRT requirements

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The ACR makes a strong case for the inclusion of appropriateness criteria linked to clinical decision support (CDS) in computerized physician order entry (CPOE) in its comment letter on proposed 2015 edition EHR certification criteria from the Office of the National Coordinator of HIT.

In comments likely to resonate across the medical specialties, the ACR comes down firmly in support of the concept of modularity in health IT, supporting the ONC’s proposal to drop the “complete” EHR certification in favor of a modular approach and throwing its support behind the proposal to divide computerized physician order entry certification criteria into three different categories (medications, lab tests and radiology/imaging).  

“A standalone certification criterion for CPOE of radiology/imaging will allow more specialized, robust order entry software to achieve modular certification for use in the EHR Incentive Program without having to add unrelated medication and lab-test ordering functionality,” write Dr. Paul H. Ellenbogen, chair, ACR Board of Chancellors, and Dr. Keith J. Dreyer, ACR Informatics Committee chair, who signed the letter.

Looking down the road to 2017, when providers will be required to consult appropriateness criteria prior to ordering advanced imaging, the ACR connected the regulatory dots for the agency responsible for implementing the federal meaningful use program in its bid to require CPOE vendors to integrate appropriateness criteria-guided clinical decision support (CDS) for radiology/imaging orders. CDS should be based on authoritative specialty society appropriateness guidelines, such as the ACR Appropriateness Criteria, which are provided via web services for integration in EHR technology, the ACR urges.

“Real world implementation has shown that robust radiology/imaging order entry systems with ACR Appropriateness Criteria-based CDS reduce inappropriate ordering behaviors, thereby improving patient safety (e.g. by reducing radiation exposure to patients), eliminating waste and reducing health care costs,” Ellenbogen and Dreyer write. “Moreover, provisions in the recently passed Protecting Access to Medicare Act of 2014 (H.R. 4302) will soon require health care providers to use said functionality for reimbursement of ordered imaging services.”

While acknowledging that the focus of CPOE is presently on documenting care within the EHR, the ACR states its belief that CPOE should ultimately be required to provide the rendering provider with structured indication for the order, and revealed plans to release a terminology set for radiology exams and indications called “ACR Commons.”

Linking transitions of care to the CPOE workflow through the use of the structured reason for order would be critical for any non-patient-facing specialists, such as diagnostic radiologists, Ellenbogen and Dreyer write.

In its comments, the ACR also responds to the ONC’s questions related to imaging and the view/download/transmit certification criterion for the 2017 edition,  referring the office to the recent recommendations of the HIT Standards Committee–Clinical Operations Workgroup for an overview of standards and methods to enable image sharing.