EHR – Certification Criteria. What is Known?

The investment in an EHR system can be significant.  Not just in terms of capital outlay, but also in workflow reorganization and training.  So it’s important that you take certain steps to make sure that your investment is going to pay off.  If part of your plan is to take advantage of the incentive payments (or to avoid the penalties) listed in the HITECH Act, then the EHR system you choose will need to be a “certified” system.

So, who will provide the certification?  Is it the already established CCHIT group which will “measure” conformity to the so called “meaningful use” criteria?  Will there be other organizations in competition with CCHIT?  How will certification be conducted?  Well, much remains to be determined, but there are some probable indications of what to expect.

Some examples of what we know are safe bets to be requirements include:

  • a medical history and problem lists,
  • the ability to provide clinical decision support for physician order entry,
  • capture and query information relevant to health care quality,
  • ability to exchange electronic health information with, and integrate such information from, other sources.

With the exception of e-prescribing, very few systems address these basic criteria, let alone the more detailed definition of meaningful use under development.  And, since for the moment, CCHIT is the only certification body in the running for this job, let’s start with them and where they’re at with their plans.  First off, here’s the pat “Wikipedia” definition for them.

“The Certification Commission for Health Information Technology (CCHIT) is a private not-for-profit organization that serves as a recognized US certification authority for electronic health records (EHR) and their networks.”

While waiting for the fed’s final definition of “meaningful use” of EHRs, CCHIT, relying on the preliminary definition recommendations put out by the HIT advisory committee, has gone ahead with it’s interpretation of what it believes those final rules will be.  While some may see this a “jumping the gun”, CCHIT, or whomever else ends up being a certifying body, needs to be ready so that they can work with EHR vendors who are wanting to coordinate sales/installations in a timeframe that allows providers to adhere to the looming deadlines if they wish to participate in the HITECH Act’s incentive program with any chance of capturing the full incentive.  To do that, providers will need to select and implement their EHR system by 2011.

CCHIT has published their Preliminary Certification Handbook, a 50 page outline, “… designed to provide health information technology certification applicants with a complete package of information necessary or you to prepare for, apply for, and achieve Preliminary ARRA 2011 certification status for your EHR technology.”  Included in it’s contents are …

  • Overview Of Preliminary ARRA 2011 Certification Program
  • The Certification Process
  • Certification Program Terms and Conditions
  • Marketing and Public Relations Policies – Preliminary ARRA
  • Forms and Documents
  • Preliminary ARRA 2011 Fee Schedule
  • CCHIT ARRA Appeal and Compliance Policy

They’ve also made available all of the necessary supporting documentation and the Certification Agreement itself.

At this point, the detail provided in CCHIT’s documents are as close of a picture as we’re going to get to the “real  deal” when the rules are finalized.  And my guess is that, while there are likely to be some changes, the overall package has taken considerable shape.

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Thomas M. Lee, Partner

Mr. Thomas M. Lee has over 35 years of experience in the business of healthcare with special emphasis in operations management, financial analysis, financial forecasting, construction projects, and new program development.