The Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) recently announced their proposed criteria for the 2015 edition of the EHR Certification regulations. It includes a new rule proposing certain voluntary certification criteria that are meant to shift the ONC’s regulatory agenda to something more frequent and incremental. The ONC claims that this approach would be easier on all stakeholders and lead to more effective deployment of heath IT, but the 2015 edition has already been criticized by the Electronic Health Record Association (EHRA).

In a letter sent to the ONC, the EHRA objected specifically to two features of the new edition – the enhanced frequency of certification, and the increased standards for clinical quality measures. The letter stated “Knowing that final specifications, test scripts and tools likely will not be available until months after the final rule comes out, we and our customers actually have even less time for all this work.” They go on to call the timeframe for the 2015 edition “unrealistic” and propose delaying its implementation until 2016. It is yet to be seen whether these objections will change the criteria proposed for the 2015 edition, but it is clear that regulators and stakeholders have increasingly divergent views about the future character of certification.

New Certification Criteria Included in the 2015 Edition


  • New definitions for interoperability– In order to improve efficiency and outcomes when patients transfer from one care facility to another, documents would have to demonstrate interoperability according to separate standards for “content” and “transport.”
  • New performance standards for documents formatted in the Consolidated Clinical Document Architecture (CCDA) – The proposed standard would require EHR technology to electronically process validly formatted CCDA documents with a 95 percent success rate.
  • Changes to meaningful use (MU) regulations – the 2015 certification criteria would give the OHC more flexibility to regulate and certify health IT whose purpose falls outside the boundaries of MU. This proposed change would create separate certification modules for MU and non-MU technologies.
  • Discontinuation of the Complete EHR definition – In order to clear up confusion on the part of both providers and developers, the 2015 edition would discontinue the regulatory use of the “complete EHR definition.”
  • Development of Gap Certification – When certification criteria remain unchanged between editions, developers will be able to apply test results determined using the older criteria when the new edition is released, rather than having to completely retest.


Follow along with the experienced recruiting team at MedPartners HIM as we continue to provide updates about the 2015 edition.