Vendor alert: API deadline looms for Certified EHRs

The 21^st Century Cures Act (Cures Act) of 2016 brought major changes to the interoperability landscape. In addition to addressing the threat of information blocking in a more structured manner, the Cures Act modified the 2015 Edition health IT certification criteria to prioritize the flow of critical health data across disparate systems.

Among the most notable modifications to the voluntary certification program is a requirement to use HL7 FHIR-based application programming interfaces (APIs) to facilitate patient data exchange.

APIs are intended to allow providers and patients to exchange data “without special effort,” potentially opening up a new era of patient control over personal health data.

EHR vendors that wish to keep their 2015 Edition seal of approval must implement these API functionalities in the relevant health IT modules by Dec. 31, 2022.

Those that don’t will be subject to action by the Office of the National Coordinator (ONC), cautioned Laura M. Urioste, conformance review branch chief at the ONC.

“As we approach this deadline, it is important to remember that meeting the Certification Program requirements and avoiding non-conformities is up to each certified health IT developer,” Urioste said, in a HealthITBuzz blog post.

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By extension, that means that healthcare provider customers are responsible for double-checking that their vendors are on track to meet the conformance guidelines by the end of the year so they can remain in compliance with programs that require the use of certified EHR technology, including Promoting Interoperability (PI), the Merit-based Incentive Payment System (MIPS) programs, and certain Alternative Payment Models (APMs) in 2023.

“Eligible hospitals and clinicians participating in these programs need to use certified API technology and enable patients to access all the data elements included as part of the United States Core Data for Interoperability (USCDI) version 1 through (e)(1) certified Health IT Modules,” Urioste wrote. “Certified health IT developers who allow their products to fall out of conformity and compliance with the Certification Program put their products and their participation in the Certification Program at risk, resulting in providers being unable to meet CMS requirements.”

API implementation: Major vendors on track

As of August 2022, only five percent of certified health IT developers had updated their technology to meet the new requirements, the ONC said at the time. However, that five percent of vendors supports approximately two-thirds of inpatient users and 77 percent of ambulatory users nationwide.

That puts the majority of the provider community in a good place to continue their digital transformation and take advantage of regulatory programs and value-based care opportunities starting in 2023.

Other health IT developers serving smaller user bases may still be working on rolling out API functionality to their customers, as there is still some time for vendors to meet the deadline.  Vendors that are having difficulty can work with their ONC Authorized Certification Body to test their systems and correct any issues, but they will have to either work quickly or decide now that they will not meet the deadline.

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The ONC will not allow vendors to officially reduce the scope of a health IT module’s certification once it falls out of compliance after the end of the year. Vendors that attempt to do so could face serious consequences, such as a ban from the certification program.

Providers need to check in with vendors

For customers concerned about staying on the right side of the regulations, now is the time to have a conversation with vendor representatives. Ask about the vendor’s roadmap for integrating API functionality into their offerings and how those changes will affect the product and its workflows going forward.  If the vendor is unlikely to meet the deadline, it may be prudent to start looking for alternative technology partners.

Even for those who are already certain they will get access to API functionality by the end of the year, this is a good opportunity to consider how the new capability will impact user workflows and patient experiences.  Start thinking about integrating next-generation apps to improve communication and patient engagement, and begin planning to educate providers and patients on the new possibilities of an interconnected, application-based ecosystem.

ONC resources, including an API Certification Companion Guide and API Resource Guide, are available to help healthcare providers have informed conversations internally, and with their vendors, about taking the next step toward meaningful interoperability across the care continuum.

Jennifer Bresnick is a journalist and freelance content creator with a decade of experience in the health IT industry. Her work has focused on leveraging innovative technology tools to create value, improve health equity, and achieve the promises of the learning health system.