The expectation is that certified products provide a reasonable level of usability for the end user. The ONC 2015 Edition of Certification has additional usability principles and requirements that products are expected to adhere to. ONC and ATLs can be contacted if there is an issue about product usability or adherence to certification requirements, however, depending on the issue, they may or may not be able to compel HIT developers to make changes to the product. Thus far, CMS has not put many requirements on the source of data moving through EHR products; however it is expected that on audit, the provider could demonstrate that the information in the system is accurate both technically and clinically. Mapping is permitted if it is appropriate. Some data may be more appropriately captured through automated recording or information exchange from other sources. It is expected that you may obtain and use data from other sources in order to most accurately represent the patient's situation or status.

Are there any usability requirements for EHR vendors to adhere to a “reasonable” way to capture clinical data needed to support eCQM reporting? Example: the EHR vendor requires that clinical data can only be captured one way so that it used for eCQMs and that one way is deemed “too cumbersome” for clinicians to use. Instead, clinicians document in the EHR using their existing tools. The data is then “abstracted” from the EHR and reentered into the “required data prompts” within the EHR so that eCQMs can be reported. Is there any requirement that the data used for eCQM reporting come directly from information entered into the EHR at point of care?