Advice: Start now to appraise fitness of EHRs

Hospitals and physicians that plan to meet meaningful use eligibility for government incentives must start now to assess their technology and talk with their vendors about certification, says Erica Drazen, managing partner of consulting firm CSC's Healthcare Group.

The Office of the National Coordinator announced the final rules for the temporary certification process on June 18. Certification entities are expected to be in place by late summer.

Under the American Recovery and Reinvestment Act of 2009, hospitals will receive payments from Centers for Medicare & Medicaid Services starting in October 2010 for the successful implementation and meaningful use of EHRs. One of the key requirements is that the systems used are certified.

"Given that the process of certifying systems will start soon, providers should ask their vendors when they plan to apply for certification," Drazen recommends in a new report "Update on Certification."

"Because meaningful use incentives require a currently certified system, and the requirements will increase in 2013, system purchases and implementation plans should consider current and expected future requirements," Drazen says.

Drazen gleans highlights of the temporary certification process as outlined by ONC:

  • Certification covers ambulatory and inpatient systems, and both vendor-supplied and self-developed systems.
  • Complete EHR systems (meeting all the certification requirements) or EHR modules (meeting the requirements of one required capability) can be certified.
  • A module must cover one complete criterion. For example, the module would have to provide all three types of required decision support in CPOE.
  • If purchasing certified modules, the end user is responsible for ensuring that these modules will integrate together to meet meaningful use requirements.
  • Systems will be certified as providing specific types of quality reporting.
  • Systems must have been certified within 12 months of their donation to obtain an exemption under the Stark rules.
  • Vendors will need to recertify that systems meet new requirements at each stage.
  • Systems certified under Stage 1 may need to be upgraded to meet meaningful use incentive requirements in 2013.
  • Authorized Testing and Certification Bodies (ATCBs) must have the capability to test and certify systems remotely. They may also offer onsite testing at their facility, a development facility or a user site.
  • Systems do not need to be implemented at a user site to be certified.
  • Testing involves an objective assessment of whether all the requirements specified by the Secretary of Health and Human Services are met.
  • After testing, systems will be certified based on test results
  • To ensure that all testing organizations are producing similar results, testing tools and techniques for all the Stage 1 criteria are being developed by the National Institute of Standards and Technology (NIST). The current versions are available for review and comment on NISTs website (www.nist.gov).
  • ONC will approve all testing tools and techniques from NIST and other sources. ATCBs will use these tools in creating testing scenarios.

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