Switching EMR and EHR Software

I’ve long been concerned about the challenge of switching EHR software. I’ve recently got into some discussions with people asking why EHR certification and meaningful use didn’t require EHR data portability as part of the requirement.

I’d forgotten that Jerome Carter had pointed out in a previous EHR switching post where HHS asked for comments on EHR data portability in the proposed certification rule for EHR (PDF) under the section “Request for Additional Comments”. Here’s his comment with the page number that addresses it:

John, this series of posts on changing EHR systems is interesting. The data issues that arise when switching EHRs can catch providers off guard. In reading through the proposed certification rules for EHRs, I found a section on data portability that you might find interesting. It is on page 13872.

Link: http://www.gpo.gov/fdsys/pkg/FR-2012-03-07/pdf/2012-4430.pdf

It’s an interesting section to read. The key is that they acknowledge the need to have some EHR data portability if you’re a doctor. Then, they look at these 4 questions:
1. Is the consolidated CDA enough?
2. How much EHR data do you need to move to the new EHR?
3. Could they start with an incremental approach that could expand later?
4. What are the security issues of being able to easily export you EHR data?

These are all good questions. I’d answer them simply:
1. Is the consolidated CDA enough?
No, you need more.

2. How much EHR data do you need to move to the new EHR?
All. Otherwise, you have to keep the old EHR running and what if that old EHR is GONE.

3. Could they start with an incremental approach that could expand later?
I think they need to go all in with this. The consolidated CDA is basically an incremental approach already.

4. What are the security issues of being able to easily export you EHR data?
I always love to follow it with the opposite, what are the issues of not having this EHR data portability available? You do have to be careful when you can export all of your EHR data, but the security is manageable.

What are your thoughts on EHR data portability? I’d still love to find a way to help solve this problem. It’s a big one that would provide amazing value.