There's a good chance the federal incentive funding has encouraged you to finally invest in an EHR. But not just any old EHR. Don't forget that to qualify for that cash, you have to select — and meaningfully use — certified EHR technology.
But what does that really mean, "certified EHR technology?"
There is considerable confusion around the phrase, as practices try to understand what's considered certified under the federal program, who is doing the certifying, and what they need to know to make sure they are eligible for those incentive payments.
There's little confusion, however, that it's necessary. Nearly 90 percent of providers surveyed last summer by consulting firm CapSite said EHR certification was "important" or "very important" when evaluating products. Yet just over half of respondents said they thought certification for the meaningful use program must be only through the well-known Certification Commission for Health Information Technology (CCHIT) program to receive funds. And no, that's not the case. More on that later.
It's also not enough to rely solely on CMS' list of certified products or your vendor's word, although both are good starts. Here's your guide to the who, what, and how of EHR certification.
The program nitty gritty
EHR certification is nothing new, and you've probably heard of or purchased a system with the CCHIT seal of approval. However, this isn't the same certification necessary for federal bonus cash.
Confused? So are your colleagues.
CCHIT chair Karen Bell called this "the largest area of confusion that's out there," speaking to Physicians Practice for a podcast on the topic.
CCHIT's EHR certification program is more robust, Bell explains, and contains review of other criteria, such as those defining security, integration, and specialties. The federal government's EHR certification for meaningful use reviews different criteria.
"It's a very specific definition developed by the federal government in order to ensure that providers, both clinicians [and hospitals], can qualify for meaningful use incentive payments," says Bell, who is also an internal medicine physician. "The law is very specific that the certification process for meaningful use must be limited to the requirements necessary to get and support meaningful use."
CCHIT is also not the only one doling out meaningful use certifications. At press time, six organizations have been approved by the Office of the National Coordinator for Health IT as authorized testing and certification bodies (known as ONC-ATCBs): CCHIT, Drummond Group, InfoGuard Laboratories Inc., Surescripts LLC, ICSA Labs, and SLI Global Solutions. Remember, just because a system has received certification under an existing program doesn't mean it is automatically certified for the meaningful use program. "There is no grandfathering of existing certification programs," says Kyle Meadors, director of EHR testing at Drummond Group.
You may have also heard that CMS' certification program is only a temporary program now. That's true. The ONC developed a temporary program to make sure certified technology would be tested and available to qualify for incentives starting in 2011. That program will be in effect until a permanent one is established, which CMS says will happen no sooner than January 2012.
Practices don't need to worry too much about the difference between the two programs, Meadors says. Just make sure your product is certified, and remains certified as the program evolves.
You also have options when it comes to which technologies can be certified under the meaningful use criteria. One route is to have a single, full-fledged EHR system that encompasses every item on the meaningful use list.
Or, you can piece together several different technologies, or "modules," to meet the requirements.
Each module you use must perform at least one of the duties required to achieve meaningful use, Bell explains. "You can have 20 different products that all come together as long as each one of those products can be certified to at least one of the criteria," she says. "It does allow certain physicians … to try different things [and] to work with them on their own."
What if you're a technology hobbier and have created your own solution? It would be up to you to understand the criteria (and what you need to do to demonstrate them) and submit your product to an authorized testing body for certification.
The list of certified products grows almost daily, and the ONC keeps a running list online here: http://onc-chpl.force.com/ehrcert. Each product is given a certification number, and the tally includes product name, vendor, version, and a checklist of the criteria the product met.
A few points
Now that we've covered the basics, here are a few points of advice:
Consider why you're investing in an EHR. Bell suggests every practice be very clear on why they are purchasing an EHR. Besides helping with the long-term implementation and work flow efforts, this introspection can help guide the selection. "If they are doing it to get incentives, if they are doing it for meaningful use, they will need that approval, but if they are looking for a long-term investment, they most likely will want a product with both certifications," she says, referring to the CCHIT certification and the meaningful use certification.
Susan Miller, administrator of Family Practice Associates of Lexington, Ky., and past commissioner of CCHIT, agrees. Having the CCHIT seal of approval first "tells you that the functionality, interoperability, and security are going to be there," she says. Then you can make sure it's certified for meaningful use, she says, which has less stringent criteria.
Talk to your vendor. Many practices are relying on the vendors to do the certification legwork, which is fine (you are, of course, busy running a practice) — just make sure to stay on top of their actions and understand the process. "I think their vendor needs to be pretty aggressive in terms of making it clear the steps a practice needs to take," Miller says. "If you aren't hearing anything from your vendor at this point, if they can't sit down and tell you the steps they are going through, that's a red flag." When talking with your vendor, be clear on which certification the company is referring to, says Lydia Washington, director of practice leadership at the American Health Information Management Association. Are they indeed certified under the meaningful use program?
Protect yourself in the contract. Washington also advises practices to consider how the program will change in coming years — and include those provisions in the EHR contract with the vendor. The product you select, as well as the vendor, should be able to support the program's evolution. "It's really important for them to understand the process is going to change," she says. "Make certain their contracts are as air tight as they can possibly be in terms of letting them progress with the meaningful use criteria and that their vendors can live up to that."
Review the ONC's product list carefully. The ONC's list is the best source for certified products, Meadors says. Between product versions and modules, it can be a little overwhelming, but Meadors adds that CMS and the ONC "are trying to help reduce the confusion." The ONC also has a frequently asked questions site detailing the certification program.
Sara Michael is editorial director for Diagnostic Imaging. She can be reached at [email protected].
This article originally appeared in the March 2011 issue of Physicians Practice.