Do You Need a "Certified" EHR?

With increasing pressure to implement an EHR and the changes that have taken place in the discussion about qualifying for ARRA funds, knowing what steps to take can be confusing. At PCC, we are working to create a number of straightforward articles about the topics of eligibility, Certification, and Meaningful Use, specifically focusing on private practice pediatricians who may qualify for Medicaid incentives.

There are many concerns that accompany the decision to pursue ARRA funding or not, beginning first with the question, am I eligible? Once you determine whether or not you're eligible, qualification for Medicaid incentives is additionally dependent upon use of a “Certified EHR” and proof of being a “Meaningful” EHR user. This article will focus on the topic of Certification, and we will tackle Meaningful Use in the next article.

Certified EHR Technology

In order to receive ARRA funding, physicians must adopt, update, or implement “Certified” EHR technology. The Office of the National Coordinator for Health Information Technology (ONC) defines and establishes the criteria for certification. An Interim Final Rule was issued on December 30, 2009 to set an initial set of criteria for electronic health information technology that is secure, has the capability to share information with other systems, and can perform a set of well-defined functions. This rule was published in the Federal Register on January 13, 2010. 

These initial criteria are available online and open for public comment until March 15. While they are not yet finalized, we have outlined some important points below:

HHS Certification is Not Simply Equivalent to CCHIT Certification

There will be multiple organizations offering HHS EHR Certification. The National Institute of Standards and Technology (NIST) has hired a consulting company to help establish a process for certifying electronic health record systems. In the meantime, CCHIT is preparing to offer preliminary EHR Certification beginning on February 12. This preliminary certification does not have the HHS stamp of approval, and products being "certified" under CCHIT's program are not HHS Certified.

In short, CCHIT certified vendors have done some preliminary guessing to determine whether or not their products will meet the new criteria. It will take some time before HHS Certified products begin to emerge.

Certification Criteria is Not Yet Final 

These recently published criteria are considered preliminary because they have not yet been finalized by HHS. Because of this, we urge you to be wary of guarantees offered by vendors claiming to meet Certification criteria that has not yet been finalized. These guarantees are often not backed by anything and most do not apply to pediatricians.

Also, do not assume that any certified product will allow you to meet the Meaningful Use criteria. Certification and Meaningful Use are closely tied, but providers qualifying under the Medicaid guidelines may be additionaly required to comply with state based criteria not spelled out in the Certification guidelines. Therefore, the ability to meet state-based requirements cannot be tested in the Certification Process.

Do You Need a Certified Product?

Even after you determine that you qualify for ARRA funds, there are still many considerations for whether or not you will actually receive funding, some of which are yet to be determined. PCC has recommended from the start that you choose the EHR that makes you the happiest and implement it within the time frame that makes the most sense for your practice. In short, we think no amount of government funding will make up for choosing the wrong EHR for your practice. 

However, PCC does intend to become a Certified Product. We have reviewed the criteria and plan to apply as soon as we feel we are ready. We already meet many of the criteria but still have a few to work on. Because we know offices are anxious about the ARRA money, we plan to work any outstanding items into our release early, release often development path quickly.  

PCC will not apply for EHR Certification until we know we are ready in order to keep the costs of PCC EHR low. The cost of certifying through CCHIT is between $33,000-$37,000  and there are additional costs for re-testing if adjustments that will take more than 90 days to complete are needed. If your practice is anxious to have a Certified product and do not want to wait for your vendor of choice to complete the certification process, you have the option of self-certifying. With self-certifying, you may combine functionality from several products that work together in your office in order to meet all of the certification criteria. 

PCC continues to follow the developments in EHR Certification and we encourage you to make your voice as pediatricians heard. Consider submitting a public comment. We also urge pediatricians to stay informed about these issues and be wary of buying decisions made under the influence of criteria that has yet to be finalized.