Do You Need a "Certified" EHR?

Updated 09/03/2010 by Erica Greenwood

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. The final rule on Certification was published to the Federal Register on July 28, 2010.  This rule is designed to set 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.  

These full list of criteria is available online.  Below, we have outlined some important points for Pediatricians:

HHS Certification is Not Simply Equivalent to CCHIT Certification

The National Institute of Standards and Technology (NIST) hired a consulting company to help establish a process for certifying electronic health record systems. It was proposed to create a temporary certification program which would eventually be replaced by a permanent program. On August 30th, the HHS Press Office announced the establishment of two ONC-Authorized Testing and Certification Bodies (ONC-ACTBs). ONC-ACTBs are temporary certifying organizations that will test and certify EHR products based on criteria outlined in the final rule. There may eventually be more organizations offering HHS EHR Certification. 

CCHIT is one of the two ONC-ACTBs and is preparing to begin accepting vendor applications for HHS EHR Certification after their town hall meeting on September 20, 2010. CCHIT's ambulatory EHR certification is different from the HHS EHR Certification and does not have the HHS stamp of approval so products that were certified by CCHIT prior to this new HHS EHR Certification program became available are not HHS Certified and will need to undergo testing in order to be considered "Certified EHR Technology" for the purposes of attaining ARRA EHR Incentive money.

Some CCHIT certified vendors applied for and attained a Preliminary ARRA Certification through CCHIT.  This program is not HHS Certified.  This program was an attempt by CCHIT and vendors to pre-determine whether or not their products will meet the new criteria. Products will need to be re-tested and certified under the actual program in order to be considered "Certified EHR Technology."

There are NO Certified Products - Beware of Certification Guarantees

As of September 2, 2010, there are no Certified products.  The certificaiton criteria was only recently finalized by HHS and the announcement of two initial certifying bodies happened only days ago.  Many vendors are anxious to attain certification and we have seen many examples of confusing marketing attempts to make you feel confident that products will meet the criteria.  We urge you to be wary of guarantees offered by vendors claiming to meet Certification criteria. These guarantees are often not backed by anything and most do not apply to pediatricians.  For more specific shopping tips, see my recent article ARRA EHR Incentive Money Myths and Shopping Tips for 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 stay informed about these issues and be wary of buying decisions made under the influence of anxious vendors and the tempting promise of incentive money.

For more on this topic visit: http://www.pedsource.com/ehrmoney