Legal Writing

A Response to the ONC's RFI on EHR Reporting: Part 2

A response to the Office of the National Coordinator's request for information on their EHR Request for Information – 21st Century Cures Act EHR Reporting Program.

KLAS Research is pleased to submit additional comments on the request for information (RFI) published in the Federal Register on August 24th on the Electronic Health Record (EHR) Reporting Program established under Section 4002 of the 21st Century Cures Act.

KLAS is a consumer research company, focused specifically on healthcare information technology products and services.  For over twenty years KLAS has shared the voice of healthcare providers through capturing and reporting their collective experiences with HIT. All rating and summary report information are available online at no charge to healthcare providers.

While KLAS does not obtain all elements of reporting suggested in the Categories for EHR Reporting Program, we do seek and obtain many.  With that in mind, we would recommend the following:

  • Discourage duplication of information available in the market.

     

    Information already available in the industry, either through KLAS or other research firms, should be seriously considered as an acceptable source of insight and information for healthcare providers and not be duplicated in the EHR Reporting Program. 

     

    Such duplication would be costly to obtain and distribute and would be unnecessary given available information in the market. (A list of available KLAS resources is provided below as Appendix A).

     

  • Provide EHR cost comparison.
  •  

    Clear cost information for software acquisition, implementation, ongoing support, and upgrades should be captured by the ONC. 

    This information is challenging to acquire from providers, given the large variety of arrangements and the complexity of implementation and ongoing support.  Vendors may be the best source of this information where providing such information could be a requirement of EHR certification. A system of noting costs based on a scale using symbols like “$$$” might be considered.

    KLAS also participated in the review of the RFI performed by the College of Healthcare Information Management Executives (CHIME).  We are supportive of all recommendations submitted by CHIME.

    We are appreciative of this effort to improve transparency in the market and feel that ONC-produced information could provide, through requirement, additional useful information on EHR costs to the healthcare market.  Such data, coupled with existing research on product function and usability, as provided by KLAS and others, would provide even more clarity for healthcare organizations.

    Thank you for your interest in our feedback.  We are happy to discuss these recommendation and our research with any who would find it beneficial. 

     

    Sincerely,

    Adam Gale, President
    KLAS Research





    Appendix A

    KLAS Research Overview

    Through over 20,000 personal interviews a year, KLAS provides both qualitative and quantitative research in the following healthcare IT categories:

    • Software
      • EMR Solutions
      • Ancillary Solutions
      • Pharmacy Solutions
      • Clinical Care Support Tools
      • Interoperability and Middleware
      • Communications
      • Physician Practice Solutions
      • Post-Acute Care Solutions
      • Outpatient
      • Patient Accounting
      • Business Analytics
      • ERP and Human Capital Management
      • HIM Solutions
      • Asset Tracking and Management
      • Population Health
      • Patient Engagement
    • Security
    • Services and Consulting
      • IT Advisory Services
      • Healthcare Management Consulting
      • HIM Services
      • Implementation Services
      • IT Outsourcing
      • Revenue Cycle Services
      • Technical Services
    • Imaging Systems and Equipment
    • Payer Solutions

     

    KLAS displays the results of these research findings on our website to assist providers in HIT decisions.  In addition to research ratings and related anonymized comments, KLAS also performs focused research in areas of specific and timely interest to the industry.  The focus and purpose of this research and reporting is to assist providers in their purchase decisions through differentiation of vendor performance based on the experience of provider peers.

    A sampling of recent KLAS reports is as follows:

    • Opioid Management
    • PACS
    • EHR Mastery: The Impact of Training
    • Medical Device Security
    • Behavioral Health
    • Interoperability
    • Remote Patient Monitoring
    • Ambulatory Therapy/Rehab
    • Clinical Documentation Improvement
    • Release of Information
    • Patient Access
    • Worksite Health Services
    • Physician Scheduling
    • Nurse & Staff Scheduling
    • Healthcare Business Intelligence
    • Emerging HCIT Companies
    • Go-Live Support
    • Smart Pumps
    • Precision Medicine
    • Digital Rounding
    • Patient Accounting
    • Post-Acute Care
    • Credentialing
    • Community HIS
    • Ambulatory EMR Usability

     

    Standard questions asked in KLAS research include the following:

    • Product functions/services delivered as sold in the demonstration and contract?
    • Received your money’s worth?
    • Avoids charging for every little thing?
    • Effectiveness of implementation services?
    • Quality and effectiveness of training?
    • Overall product quality, including upgrades?
    • Delivers new technology that meets your needs?
    • Ease of use for end users?
    • Product supports your organization’s integration (interoperability) goals?
    • Current product functionality meets all your needs today?
    • Quality and effectiveness of post-implementation support?
    • Service is genuinely proactive?
    • Vendor executive involvement?
    • Keeps all promises?
    • Product is part of your long-term plans?
    • Recommend to a peer or friend?
    • Drives tangible outcomes?
    • Overall satisfaction?
    • Forecasted satisfaction in 12 months?
    • Would you buy this again?

     

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