Context Should Be Considered in Recent GAO Report on VA EHR Rollout

GAO’s report entitled “Electronic Health Records: VA Has Made Progress in Preparing for New System, but Subsequent Test Findings Will Need to Be Addressed”, recommends that VA postpone deployment of the Cerner EHR at planned locations until it resolves “critical and high severity test findings.”

VA is in the midst of a massive EHR replacement project spanning ten years and totaling $16 billion. VA is in the process of implementing Cerner’s commercial Millennium EHR at over 1,500 medical facilities, replacing the current homegrown Veterans Health Information Systems and Technology Architecture (VistA) which is over 30 years old. Cutover of the first site at the Mann-Grandstaff medical center in Spokane, WA occurred October 24, 2020.

GAO’s recent report stated that VA showed progress toward implementing its new EHR system by “making system configuration decisions, developing system capabilities and system interfaces, conducting end user training, and completing system testing events.” The report also stated that VA had not yet resolved all critical severity test findings and high severity test findings, as called for in its testing plan.

What is not readily obvious about GAO’s report is that the organization’s analysis of VA’s progress took place from August 2019 through September 2020 in preparation for a Congressional briefing held on October 22, 2020. The majority of the report is a summary of the briefing, which took place prior to the go-live at Mann-Grandstaff.  The actual briefing documents are included as an appendix to GAO’s report. GAO’s findings and briefing are only now being released publicly.

As of late September, GAO’s analysis showed 17 critical severity test findings and 361 high severity test findings remained open. Due to these findings, GAO believed VA was “at risk of deploying a system that did not perform as intended and could negatively impact the likelihood of its successful adoption by users if these test findings were not resolved prior to initial deployment.”

At the time, GAO recommended that VA delay deployment of the new EHR until the critical severity test findings were resolved and the high severity findings were addressed. VA was able to close all critical severity test findings and go on to deploy the new EHR system at Mann Grandstaff on October 24, 2020. VA also addressed 306 of the 361 high severity test findings prior to the go-live. GAO’s report states that “VA’s actions reflect implementation of GAO’s October recommendations.”

GAO’s report states, “VA will likely identify new critical and high severity test findings,” as it moves forward with future deployments at other locations. The report goes on to caution, “If VA does not close or appropriately address all critical and high severity test findings prior to deploying at future locations, the system may not perform as intended.”

In VA’s response to GAO regarding the report prior to publication, the department suggested that GAO change part of the title of the report from “’…but Subsequent Test Findings Will Need to Be Addressed’ to ‘..and Test Findings are being Addressed.’” However, GAO decided to keep its original report title.  

VA concurred in principle with both of GAO’s recommendations. A summary of GAO’s recommendations and VA’s comments are below:

GAO’s Recommendations: VA should postpone deployment of the new EHR in new locations until all existing open critical severity test findings are resolved and closed, and high severity test findings are either resolved,  closed or deferred.  

VA’s Comment: VA stated that it already resolves and closes critical severity test findings prior to deployment. VA also stated that it closes, resolves or defers high severity test findings prior to deployment. VA will continue to test and adjudicate findings. In the meantime, VA will continue to launch the EHR as planned.

VA’s next system deployment is planned for the Puget Sound Health Care System in the 4th quarter of FY 2021.