There are now three paths to certification, and three different certification types therein:
- 1) EHR-C - which stands for EHR Comprehensive
- 2) EHR-M - which stands for EHR Module
- 3) EHR-S - which stands for EHR Site
Comprehensive - "Rigorous certification of comprehensive EHR systems that significantly exceed minimum Federal standards requirements." Needs to meet all of the Meaningful Use Objectives.
Module - "Flexible certification of Federal standards compliance for EHR, HIE, eRx, PHR, Registry and other EHR-related technologies." Needs to meet one or more of the Meaningful Use Objectives. Applies to many specialty-specific EMRs.
Site - "Simplified, low cost certification of EHR technologies in use at a specific site." Applies to "any physician office, clinic, hospital, other facility or network that has self-developed or assembled an EHR from various sources and wishes to apply to ARRA incentives."
Process of Applying for ARRA Incentive Payments
- Certification by CCHIT allots various certification "codes" to the EHR vendor -- which apply specifically, and exclusively, to that vendor, and vary depending on the corresponding status (EHR-C versus -M versus -S have different codes) . These are then conveyed to the health care provider upon usage.
- Health care provider submits these codes in their ARRA incentive payment application.
- Health care provider must also submit additional "measure data" required for ARRA's own definition "meaningful use" (separate from CCHIT criteria).
- Providers do not apply to CCHIT for the incentive payment; they apply to HHS. The means by which this will be done is still unclear, and has not yet been stipulated. Will it be a contractor? An online site? Via regional extension centers? What we do know is it will be through some government-named body that will 1) accept CCHIT codes and provider application; 2) assess, reject or accept quality measure data; 3) send or withhold the incentive check.
- EHR-M status can be awarded to groups of vendors. If certification is awarded to a group of vendors, they collectively must cover all (as opposed to one, or a few) Meaningful Use Objectives.
- Certification awarded in two year increments.
- Certification no longer "locked" into a software's parent version; all upgrades that maintain the previously approved Meaningful Use Objectives maintain those corresponding approval codes.
- A provider's site can be certified as EHR-S, even if the EHR software has not been approved as EHR-C or EHR-M. If a site uses an EHR-C or EHR-M, then it is certified as an EHR-S. The converse, however, is not true: EHR-S does not confer -M or -C certification status onto the software in use.
- CCHIT testing will begin in September of 2009. There will be no freestanding certification for 2009-2010. All testing will be geared toward the ARRA requirements for the upcoming 2011-2012 period. In other words, there will be no maintenance of any old CCHIT certification. (Click here for more on ARRA timing.)
Complete CCHIT Presentation slide show available here.