Making an EHR sale takes time and resources. Once a sale is made, client sites provide vendors with a steady stream of income. Client sites that decide to switch from one EHR to another will find vendors less than eager to see them go. Though data migration options should be included in contraction negotiations, it is a subject few are comfortable broaching. Like discussing a pre-nup immediately after proposing, discussing ways to move data to a different EHR when negotiating a contract seems to be in bad taste. As a result, tales of data migration woes–costly migration services or manual data re-entry, are common.
I have often wondered to what degree data-migration fears prevent practices from switching EHR systems. Fortunately, it looks like the folks at ONC are wondering the same thing. Buried in the newly released proposed rule for EHR certification (page 13872) is this intriguing paragraph:
D. Data Portability
We seek public comment on whether we should adopt a certification criterion that focuses on the portability of data stored within CEHRT. When a provider seeks to change EHR technology, we believe that they should have the ability to easily switch EHR technology—at a low cost—and migrate most or all of their data in structured form to another EHR technology. In the absence of this capability, providers may be ‘‘locked-in’’ to their current EHR technology. This could ultimately impede innovation and is a key aspect of the EHR technology market that requires significant maturity.
Requiring data portability, in future EHRs would be a welcome, clinician-friendly certification requirement. However, besides portability, there are additional data issues that are potentially problematic.
Metadata is essential for e-discovery requirements. There is so much metadata associated with an EHR (e.g. EHR audit trial, operating system logs, database logs) that all of it cannot easily be moved. Therefore, meeting e-discovery requirements will require that practices archive data until legal statute time limits have passed. For SaaS EHRs, this might require maintaining a subscription for an unused EHR in order to maintain access.
Adding data portability functionality that permits migration of all or substantial amounts of EHR data will not be cheap. How much will vendors charge for this feature? ONC cannot insist that it is free, only that it is available.
Preventing tampering or accidental alteration of migrated data sets will be important. After all, no one is going to manually check every element of imported data against the original. Import functions will have to be robust in order to avoid errors.
If it becomes significantly easier for clinicians to switch EHRs, how will vendors react? Will licensing fees increase to maintain revenues or decrease to gain new clients? Will data portability improve customer support quality because vendors become more responsive in order to prevent losing clients? Vendors with a large market share might be against this feature because it makes it easier for their clients to move on. On the other hand, smaller firms and those just entering the market might well be for it because it would allow them to use pricing and service quality to attract the disgruntled customers of larger vendors.
Despite the above concerns, I see a definite upside to requiring data portability functionality in certified EHRs. By ensuring that clinicians are not trapped in unproductive vendor relationships or with outdated technology, the ONC may actually foster innovation in the EHR market.
All things considered, if this functionality becomes a certification requirement there should be fewer practices trapped in marriages of convenience. If so, messy data divorces will be one less thing clinicians have to worry about.