Tuesday, June 16, 2009

The Latest from CCHIT: "New Paths to Certification" (Recap)

If you didn't have time to take part in today's Town Call with CCHIT (or, if you did, and would like a pared-down recapitulation), here is a list of major points worth knowing:

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
All three constitute certification, but differ in their requirements.

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).
Other Info / Points of Clarification
  • 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.)
If you have additional questions, you can email dwilson@cchit.org, me, or you can submit your comment below.

Complete CCHIT Presentation slide show available here.

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