Drummond Advisory Services Newsletter – Q3 2022

Drummond Advisory Services Newsletter – Q3 2022

In this issue:
  1. Notable dates and deadlines
  2. RWT results reports and plans
  3. (G)(10) FHIR® consultations
  4. Coming soon: 2023 ONC compliance lifecycle activities

Notable dates and deadlines

Drummond Advisory Services has been working with customers on accelerating key ONC compliance initiatives in recent months. Here are some updates on what we have learned in recent collaborations along with guidance on areas where our team may help with approaching deadlines.

Real World Testing (RWT) plans for 2023: Due to Drummond’s Authorized Certification Body (ACB) no later than Nov. 1

RWT results report for 2022: Due to Drummond’s ACB no later than Feb. 1, 2023

Certification to §170.315 (g)(10) Standardized API for Patient and Population Services: Live test session must be completed no later than Dec. 16 (early testing highly recommended)

Attestation to 2015 Cures update revised criteria: Submission to Drummond ACB no later than Dec. 16

Semi-annual attestations: Open Oct. 1-31 –A corrective action will be issued to health IT software developers who do not respond; may result in ONC direct review

RWT results reports and plans

Advisory Services is engaged with developers as they gather, review and analyze RWT results data. We leverage ONC’s recently published results report template while considering the customer’s individual approach to testing. We can help assess your team’s needs, provide expert reviews and build a scheduled plan to collaborate with you on a successful submission.

Key Advisory Services for RWT results reporting include:

  • Reviewing the traceability of metrics that measure activity over time
  • Analyzing test plan workflows for criteria that may have had little to no adoption, yet still must be tested
  • Identifying and remediating gaps in testing results to ensure results data fully aligns with published 2022 RWT test plans
  • Documenting necessary testing process changes for consideration in the results report and 2023 RWT plans, including test plan “exceptions” and “hardship” explanations discovered during testing this year

Drummond customers seeking assistance with results reporting are encouraged to contact our team to discuss the status of your RWT results gathering, reporting and planning for 2023.

RWT plan development

RWT plan submissions are an annual requirement. Our team offers consulting services for test plan development to address the 2023 test plans due to the ONC-ACB by Nov. 1. Drummond Advisory Services recommends developers account for various considerations and changes that may apply to their 2023 test plans, including (but not necessarily limited to):

  • SVAP adoptions and deployment
  • New FHIR® API infrastructure
  • Changes in technology
  • New approaches to testing discovered over the past year

Our team welcomes inquiries about our test plan writing service to help you meet the Nov. 1 submission deadline.

To best meet customers’ needs, Advisory Services can combine Fall 2022 RWT services into a single 60-day project for customers – reviewing recent testing activities and results, identifying changes for 2023 Test Plans (by Nov. 1), providing quality assurance for all documentation and guiding organizations to on-time completion of the two required RWT written deliverables: the 2023 plan and the 2022 results report.

Email advisoryservices@drummondgroup.com to discuss your Q4 RWT needs.

(G)(10) FHIR® consultations

Advisory Services launched its (g)(10) FHIR® consulting program earlier this year and is now actively consulting with developers in various stages of development.

We have provided guidance for customers in earlier planning and development stages of their (g)(10) initiatives by addressing certification requirements and tools, discussing implementation requirements, assessing “build vs. buy” options and conducting pre-testing.

As the (g)(10) deadline nears, Advisory Services is increasingly focused on some specific customer needs:

  • Providing gap analysis on (g)(10) development efforts projects with focused analysis and remediation of missing requirements
  • Conducting multiple rounds of pre-testing with Inferno or the newly approved Touchstone alternative test method
  • Troubleshooting and remediating testing errors observed in pre-testing
  • Assessing “build on” and “buy” options for use of third-party components and solutions to assist developers facing challenges with completion against nearing deadlines

We recommend customers target readiness for live testing with Drummond’s Accredited Test Lab (ATL) no later than Nov. 15 to provide a cushion for unexpected issues. Stronger assurances for successful live testing can come through tight engagement with Advisory Services on pre-testing, gap analysis and troubleshooting in advance of your live test event.

We can build 45- to 60-day project plans with customers to combine consulting and pre-testing assistance that accelerates an organization’s progress toward meeting the (g)(10) deadlines. In addition, Advisory Services will help build plans to utilize third-party FHIR® technology if customers choose to explore that path.

Coming soon: 2023 ONC compliance lifecycle activities 

Advisory Services is preparing for 2023 and building programs to help our customers on an ongoing basis.

“Conditions of Certification” will be a key focus area going into next year to help customers plan and manage the activities that will extend throughout the annual lifecycle:

  • RWT guidance after ONC results review commences next year
  • Semi-annual and quarterly self-attestation reviews
  • Information blocking rules and their implications
  • Managing development through the SVAP process
  • New rulemaking, especially for “prior authorization”
  • Next year’s §170.315(b)(10) deadline (electronic health information export compliance)
  • And more . . .

An October webinar will provide an opportunity to hear more about our vision of key compliance lifecycle activities and management considerations for 2023. Webinar details to be announced soon!

Disclaimer: The services offered by Drummond Advisory Services are separate and distinct from the Drummond Group Test Lab and Certification Body. The purpose of Drummond Advisory Services is to provide expert support and guidance for the planning, analysis, and execution of certification activities; it does not negate the steps or required actions of the certification process. Use of Drummond Advisory Services does not guarantee successful ONC Health IT testing or certification.

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