EHR Association Concerns about Proposed USCDI V2 Standard

by | Jul 15, 2022

Electronic Health Record Association have recently commented on the Standards Version Advancement Process (SVAP), a set of regulations that allows health IT developers be given the ability to adjust health IT related product’s standards. SVAP was developed by OCR with the aim of giving developers a greater level of flexibility and to use their initiative to adopt new, certified standards as they go. At present, SVAP is working to release frequent comment periods in which they focus on updated standard of a high priority, including the United States Core Data for Interoperability (USCDI), however, they have encountered pushback in recent months.

 Initial Advice of EHR Association

On October 11, 2021, EHR Association wrote to Micky Tripathi, the current National Coordinator for Health Information Technology. The association commented on a proposed delay to SVAP, stating what they supported and what they were concerned by within the proposal. EHR association were understanding of the need to delay USCDI V2, but disapproved of the proposed delay to other aspects, arguing that the progress of developers to adjust to newer versions in the most optimal way. HER Association proposed that SVAP proceed with the initial plan involving the adaptation of new standards (excluding USCDI V2) in January of 2022. Following this an evaluation would take place in May of that year with plans to announce the new standards the following month and implement by August 2022. This advice was given on behalf of thirty organizations under the EHRA umbrella, and signed by Chair of EHR Association Cerner Corporation, Hans J. Buitendijk.

What new advice has been offered by EHR Association?

On May 2 2022, EHR Association wrote another letter to Micky Tripathi, reaffirming the advice they attempted to deliver in October in the previous year. The association reminded Tripathi of the instruction to publish in May 2022, despite delays to USCDI V2. Without publishing, it was feared that guidance could not be made within the Companion Guide to account for the upcoming developments from USCDI V2. EHR association expressed their dismay towards this not being published as of May 2022, describing the situation as ‘problematic’. Problems may arise where companies adopt new adjustments from SVAP, without the knowledge regarding HL7® FHIR® US Core and HL7® CDA® C-CDA. HER Association stated that this has been a common occurrence in previous instances. In addition to this, opting to not publish may hinder organizations that wish to maintain the current companion guide regulations. The EHR Association strongly advices that the Office for Civil Rights (OCR) evaluates the relationship between USCDI and SVAP, making it a requirement for guidelines to be published prior to USCDI publishing. Another similar option brought forward in the letter by EHR Association is to ensure the SVAP comment period with the upcoming USCDI does not commence prior to the publishing of updated guidelines.

Furthermore, EHR Association have advised Micky Tripathi and SVAP of an interim plan that should be adopted. This involves elongating the existing SVAP comment period by a new deadline of thirty days following the updated companion guide to ensure a sufficient evaluation is conducted. This could either be bounded to only the USCDI V2 standards or include the publication of all other standards should the delay be too lengthy. This should include a SVAP update with an outline of USCDI V2 and any relevant supplemental guides. This plan would evade a year long set back. Finally, EHR Association advises that OCR offers more clarity within their announcements regarding candidates as the association feels recent releases of guides have been unclear.

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