Request for Public Feedback on Draft Voluntary User-Reported Criteria for the Electronic Health Record Reporting Program

This 60-day public feedback period is now closed. This page continues to be made available for public reference. Please visit the EHR Reporting Program project page for updates on the program

The 21st Century Cures Act, or Cures Act, directed the US Department of Health and Human Services to establish a new Electronic Health Record (EHR) Reporting Program. The Office of the National Coordinator for Health IT (ONC) has contracted with the Urban Institute, and its subcontractor, HealthTech Solutions, to develop the program. The EHR Reporting Program will provide publicly available, comparative information on certified health IT products that will inform health IT users’ purchasing and implementation decisions.

The program will reflect developers’ and voluntary end users’ reporting of comparative information on certified health IT. This 60-day public feedback period focuses on the draft voluntary user-reported criteria. Developer-reported criteria will be posted for public feedback at a later date.

By August 10, 2020, please submit feedback on the criteria presented in the following documents to [email protected]:

• table summarizing draft criteria for end users by topic and data source
• user questionnaire for collecting information for draft voluntary user-reported criteria

We welcome any public feedback and ask that reviewers consider the following:

• Which draft criteria would you prioritize for inclusion in the EHR Reporting Program, and why?
• Which draft criteria should be rephrased, reworded, or removed?
• Should the voluntary user-reported criteria cover only the most recent version of a certified health IT product or all versions of the product?
• What certified health IT users are most likely able to report on the criteria (e.g., clinicians, administrators, IT specialists)?
• What could motivate end users to voluntarily report on certified health IT products?

Below, we provide more information on the criteria’s development and framework.

Draft Criteria Development

We developed the draft voluntary user-reported criteria based on stakeholder engagement from August 2018 to January 2020. The framework below summarizes the stakeholder input received, which we describe in detail in a summary report.

Framework for Draft Voluntary User-Reported Criteria

Draft criteria are based on stakeholder priorities and refined through cognitive and feasibility testing and expert review. The draft criteria draw on information on specific certified health IT products from existing data sources, such as ONC’s Certified Health IT Product List (CHPL), as well as new data collection efforts from certified health IT users. New data collection is necessary because, except for the CHPL, existing data sources are limited in their ability to provide comparable information or product-level details about certified health IT. 

Testing and expert review identified some priorities as too burdensome to collect (e.g., detailed cost information) and other information (e.g., click counts) as too dependent on local implementers’ customization decisions to be useful.

While developing the criteria, we found that the usability information prioritized by stakeholders is best collected from users, whereas many stakeholder priorities from the other Cures Act categories are better collected from developers and existing data sources. Therefore, the draft voluntary user-reported criteria reflect stakeholder priorities that can be feasibly collected from users. In addition, we developed draft criteria to align with other components of the Cures Act, including reducing clinician burden and the ONC Cures Act Final Rule.