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After the passage of the HITECH Act in 2009, the medical community anxiously awaited the final regulations defining the parameters of “meaningful use” and the corresponding certification requirements for electronic health record (EHR) implementation, which were eventually announced last July.
In September, EyeNet provided a general overview of the regulations. This month, EyeNet answers seven key questions about EHR certification. See the next issue for a more detailed look at meaningful use.
Seven Key Questions
Does it matter if an EHR is certified or not? If you are purchasing an EHR with the intent of collecting the incentive bonus, your system must be certified by an Authorized Testing and Certification Body (ATCB). “According to the government, this new certification is designed to give consumers assurance that the EHR technology is capable of meeting, or allowing them to meet, the meaningful use requirements,” said Julia Lee, JD. “The two components—meaningful use and certification—go hand in hand. The only way to ensure that EHR systems actually address each and every one of the meaningful use functionalities was to create a new certification process from the ground up.” Ms. Lee chairs the AAOE subcommittee on EHRs and is executive director of Ophthalmic Partners, a multispecialty practice in the Philadelphia area.
Which EHRs are certified for meaningful use? At time of press, there were no ATCBs, so no EHR systems had been certified by an ATCB. “What we now know are the prerequisites that must be achieved in order to earn the incentive bonus. However, currently there are no certifying organizations,” said Michael X. Repka, MD. “The certifying body has been described by the Office of the National Coordinator (ONC) but that is all.” Dr. Repka is the Academy secretary for Federal Affairs and professor of ophthalmology and pediatrics at Johns Hopkins University. The ONC will create and maintain a list of EHRs as they become certified. Consumers will be able to search and find the certification status of the particular product that they are contemplating. The list will be on the HHS Health IT website.
What about EHRs that were already CCHIT certified? The Certification Commission for Health Information Technology (CCHIT) is a private organization that began certifying EHR technology in 2006. “Although CCHIT certification was never officially deemed a precursor to meaningful use certification, the expectation was that CCHIT would play a continuing role because it was the only EHR certifying body in existence,” said Ms. Lee. “It was also anticipated that perhaps those systems that were already CCHIT certified may be ‘grandfathered in’ or partially satisfy the certification requirements, but this is not the case. Having satisfied CCHIT testing does not relieve vendors of the obligation to certify under the meaningful use program. The Office of the National Coordinator wants to start from scratch and set up these bodies that look at certification through the lens of meaningful use requirements.” CCHIT has already applied to be a certifying body. Given its prior experience and the steps it had already taken, it should be approved relatively quickly.
What is the difference between temporary and permanent certification? The government is splitting certification into a temporary and permanent program. Because of the rapid approach of 2011, which is when practices can begin collecting incentive monies, the ONC created temporary certification to jump-start the certification process. “It is a phased approach,” said Ms. Lee. “Temporary certification will apply the first year of the EHR incentives, which will ensure the availability of certified EHRs for physicians who choose to begin demonstrating stage 1 meaningful use in 2011. ONC has stated that the permanent certification rule will issue in the fall and the program will be in place by 2012 so vendors can certify EHRs for 2012 and beyond. Our current understanding is that vendors will be required to recertify for each new stage of meaningful use to make sure their products have the additional functionalities to satisfy the additional requirements.”
When is it reasonable to expect EHR systems to be certified? The goal is to have as many systems certified by the beginning of 2011 as possible, so practices can begin taking advantage of the incentives. “Those vendors that have ample resources dedicated to the certification process should be among the first to become certified,” said Ms. Lee. “The momentum has increased with the release of the final rule.” At time of press, Ms. Lee expected that at least one testing body would be established by the end of summer 2010 and that several vendors would be certified by fall 2010.
Should you start EHR adoption before the certification process is complete? Moving forward with EHR implementation is a subjective decision that should be made according to each practice’s needs and goals. However, “if you have not already begun to transition, it may be best to wait and see what happens—at least for the next few months,” said Dr. Repka. “We need to see how the market responds to the rule. Practices still have plenty of time to maximize the bonus. If you’re demonstrating meaningful use by the last quarter of 2012, you’re still on track to get the entire bonus available. So take time to assess your needs and research what’s available. We now know more about the requirements, and the core set of objectives were not softened for specialties. As a result, there are 20 objectives— 15 of which are mandatory, five are at the physician’s choice—that must be performed during a routine office visit for the majority of patients, as well as three quality core measures and three selected quality measures. Even considering the penalties, some ophthalmologists may not want to participate in the incentive program at all due to the required core objectives and quality measures. It is a decision a practice must make.”
How can I ensure that a vendor will pursue and maintain certification? In order to remain viable, vendors must pursue certification. Without it, they will be unable to compete with the vendors that are certified. Protect your investment by “selecting a vendor who is pursuing certification and incorporate language into your contract that reflects this,” said Ms. Lee. Dr. Repka agreed: “In light of the final rule, this is clearly an essential part of your contract now. And it is not enough for a contract to state that a vendor is pursuing certification; the contract should also state that the vendor has a long-term commitment to maintaining certification.”(For sample contract terminology, go to www.aao.org/ehr, select “Planning and Selection,” then “Negotiate the Vendor Contract” and “Sample Language.”)
EHRs in Chicago
AT THE JOINT MEETING. Find out the latest on the EHR incentive.
VISIT THE EXHIBITION. Visit the Electronic Office (Booth 3967) to pick up info on meaningful use and for a 10-minute demo on the benefits of integrating EHRs with your devices. Go to the Academy Resource Center (Booth 2344) to see the AAOE’s latest EHR products. Attend the Technology Theater (Booth 569) on Sunday afternoon for two free presentations (see below). And make time to visit the exhibits of EHR vendors.
ATTEND AN EVENT. More than a dozen events focus on EHRs.
Saturday: EHR Selection for the Small Practice (1 to 3 p.m.; “Spe11”; $150), EHR Selection for the Mid-Sized to Large Practice (1 to 3 p.m.; “Spe12”; $150), Successful EHR Implementation for the Small Practice (3:15 to 5:15 p.m.; “Spe15”; $150) and Successful EHR Implementation for the Mid-Sized to Large Practice (3:15 to 5:15 p.m.; “Spe16”; $150).
Sunday: EHR Vendor Demonstrations—Compulink, Medflow, NextGen (12:30 to 1:30 p.m.; Technology Theater; free), EHR Implementation: Workflow Development (2 to 3 p.m.; “212”; $35) and How You Can Qualify for Meaningful Use EHR Incentive Payments of $44,000 (2 to 3:30 p.m.; Technology Theater; free).
Monday: EHRs and Compliance Programs Breakfast (7:30 to 8:30 a.m.; “B297”; $40), Cashing In on the Stimulus Program: Getting to Meaningful Use (11:30 a.m. to 12:30 p.m.; “384”; $35) and Finally, a Meaning for Meaningful Use: Learn How to Qualify for EHR Incentives (12:15 to 1:45 p.m.; “Spe57” in Room S102; free).
Tuesday: EHRs and Compliance Programs Breakfast (7:30 to 8:30 a.m.; “B497” $40), An Approach to Selecting and Implementing EHRs (9 to 10 a.m.; “518”; $35), EHRs and Compliance Programs (9 to 10 a.m.; “538”; $35), The Transition to EMR in a Retina Practice: Practical Advice from a Group That Made It Through the Hurdles (9 to 11:15 a.m.; “336”; $70) and EHR Implementation: Principles of Project Management (11:30 a.m. to 12:30 p.m.; “586”; $35).