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.
John, great post. Data portability is topic that needs to receive much more attention as EHR adoption moves forward. If you are interested, I wrote this post How Long Will You Be Married to Your EHR? a while back. It addresses issues of data portability and product lock-in.
Jerome
Great post Jerome. I left a comment on it. I also added a link to your site in the post. Thanks for reading and stopping by to comment.
EMR vendor-to-vendor interoperability is being pushed as part of MU Stage 2/Stage 3, but we are still a little ways away. Some EMR vendors are currently able to produce and consume CCDs discretely, but without coding systems standards in place the mapping of clinical data is still a significant challenge between disparate EMRs. Hopefully we will see significant improvement in EMR vendor-to-vendor interoperability over the next couple years so that this transition becomes easier and easier for providers.
Brad,
Plus, the real challenge in this article is literally switching EHR software. The CCD isn’t nearly robust enough to be able to do this. It’s great for its purpose, but doesn’t have the sophistication necessary for a full EMR export from one system to another.
Agreed, John. We have done CCD migrations, and there is definitely a fair amount of data that usually needs to be added to the CCD in order to meet the client needs for the conversion. For most discrete EMR conversions we do, the CCD as it comes out of the source EMR systems doesn’t cut. However, we are usually able to meet the client needs through customization either of the CCD, the data extracts, or the inbound interfaces.
We are also providing a lot of alternatives for customers with a limited budget or short timeline, such as a legacy EMR viewer. We created a product called PatientArchive that can be accessed directly from their new EMR that gives them read-only access to all of their legacy EMR data. Since they can access it directly, they don’t have to relogin to their old system or search for the patient again. The patient context is passed from their new EMR to PatientArchive, so all of the legacy EMR data for that patient is viewable in a single click.
Brad,
I like the idea of a legacy EMR viewer. That would work for many EMR switches. We’re going to need a whole bunch of tools like that to handle all of the EMR switching which is bound to come.
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.
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