July 6, 2023, News Staff — One important step toward reducing physicians’ administrative burdens would be adopting electronic prior authorization standards in certified EHR technology regulations, the AAFP wrote in detailed guidance to HHS’ Office of the National Coordinator for Health Information.
The ONC should integrate electronic prior authorization standards — including those automating prior authorization requests for prescription medications — into CEHRT “as soon as possible,” the Academy wrote.
“The AAFP strongly urges HHS to take steps to dramatically decrease the overall volume of prior authorization requirements. However, health information technology solutions are also needed to support real-time automation between prescribers and payers,” added the June 19 letter.
The Academy was responding to a proposed rule updating regulations for certified EHR technology, which are required for practices participating in federal programs. The rule aims its requirements primarily at system developers and vendors, but the EHR products it would govern have considerable impact on family medicine practices. As a stakeholder concerned with administrative and documentation burdens, the Academy made a number of detailed recommendations to the ONC, urging that the final rule
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The Academy expressed conditional support for the rule’s proposed new maintenance certification requirements for health IT developers, meant to promote interoperability by ensuring that systems complying with federal standards make updates rapidly available to customers. The prompt sharing of such updates could reduce administrative tasks while improving interoperability and patient access to data — but also might be “costly and disruptive to physician practices,” the letter cautioned.
“We are concerned that vendors may force practices to update their solutions more quickly than practices would like, resulting in unaffordable costs and disruption to patient care and physician workflow,” the AAFP said.
To avoid what it called the potential unintended consequences of the proposed maintenance certification mandate, the Academy said the ONC should urge health IT vendors to “update modules in consultation with their customers, including end users” while providing a “safe harbor for those customers that wish to delay implementation of the updated modules, such that the customer continues to have a certified EHR technology which is required for other HHS programs.”
To maximize utility in physician practices, the Academy said the ONC should finalize the proposed rule’s plan to clarify real-world testing reporting requirements.
“Real-world testing is critical to ensuring that health IT is effective and interoperable,” the letter said, pointing to a recent statement the AAFP co-signed as part of the Health IT End Users Alliance. “We urge ONC to finalize this proposal and to make real-world testing a mandatory requirement for all health IT developers.”
Responding to a section of the proposed rule adding a new certification criterion called “patient requested restrictions” — meant to allow patients to request that their health information be restricted from being used or disclosed, allowing them more control over their health information and to protect their privacy in line with HIPAA — the Academy said the need for such functionality was “pressing” but asked the ONC to test it before implementation.
“The AAFP strongly supports patients’ right to privacy and the need to provide differential confidentiality to support patients’ privacy,” the letter said. “However, existing technology does not meet current data segmentation needs, could lead to unintended consequences and will instead add to physicians’ administrative burdens. Any standard must be real-world tested before mandated for adoption.
“In the meantime, the AAFP recommends ONC include a certification criterion for the tracking of patient privacy and disclosure requests. This is a key missing functionality of CEHRT and one that is long overdue.”
The Academy was critical of how the Information Blocking Rule defined electronic health information and has continued to be vigilant as the rule has rolled out. The June 19 letter lauded the opportunities for refinement in the proposed rule and urged finalization of two exceptions while calling for additional guidance to ensure no new burdens.
“The AAFP strongly agrees with the inclusion of a new ‘Third Party Seeking Modification Use’ exception and agrees it should not apply to non–health care entities,” the AAFP wrote, adding that the ONC should make clear how to employ it with minimal documentation.
“We are also supportive of the inclusion of a new ‘Manner Exception Exhausted’ exception,” the letter added. “We urge ONC to clarify that, if the physician or practice provided the information in the manners supported by their CEHRT and any other manner that requires minimal effort. they should then be able to leverage the Manner Exhausted Exception.”