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Playing Games with ONC Certification

February 10, 2011 By 2 Comments


“Certified” is the $44,000 buzzword prefixing electronic health records (EHR) software. To qualify for Health Information Technology for Economic and Clincal Health (HITECH) Act incentive payments, you must use an EHR that is certified by the government. Additionally, you must use a system – or systems – that offer 100% of the functional and security capabilities required to meet “Meaningful Use” criteria.

Many EHR vendors are promoting their products as “certified,” but the claim can be misleading. There are three ways they could lead you astray:

Alternative Certifications

Before the HITECH Act, two organizations certified medical software:

  • Certification Commission for Health Information Technology (CCHIT) – CCHIT began certifying EHR software in 2006. Since then they have released 10 certification programs for ambulatory and inpatient EHRs.
  • KLAS – KLAS is a private organization that has gathered ratings on EHRs since 1997. Every year they rank EHR vendors and bestow a “Best in KLAS” award on the top 20.

In an effort to stand out from the other 300+ EHR systems on the market, vendors widely promote their CCHIT or KLAS credentials. They may even tack the word “certified” onto their CCHIT or KLAS approved product. This muddies the water for providers. They have to distinguish between CCHIT, KLAS and certification from an ONC-Authorized Testing and Certification Body (ONC-ATCB). While CCHIT and KLAS are meaningful credentials, they’re not the certifications that qualify for incentive funds.

This is especially confusing because CCHIT is now one of six organizations approved to certify EHRs for the HITECH Act. So, if an EHR vendor claims they have CCHIT certification, you’ll need to clarify which one. Is it ONC-ATCB certification, or one of CCHIT’s independent credentials?

Complete EHR vs EHR Module

Software vendors can receive ONC-ATCB certification for a complete EHR or an EHR module. This means a product doesn’t need to meet all criteria for Meaningful Use – instead, it can be partially certified if one or more functions meet a subset of requirements. For example, a vendor could certify their e-prescribing application or their patient portal.

This under-publicized detail could cost you thousands of dollars; by itself, a certified EHR module won’t make you eligible for incentive payments. You must use two or more modular EHRs that, combined, meet 100% of the ONC criteria. So while vendors can officially promote a module as having ONC-ATCB certification, it may fall short of making you eligible.

Guaranteed Incentive Payments

Be mindful of guaranteed incentive payments. It is reasonable for a vendor to guarantee they’ll meet certification criteria. In fact, you might make it a requirement in your purchase decision.

However, guaranteeing incentive payments is altogether different. Technology alone won’t make you eligible. EHRs are just a means to an end. Ultimately, you are responsible for achieving Meaningful Use status. So be wary of this type of guarantee. Read the fine print and find out how you are reimbursed if you don’t qualify for incentive payments. Does the vendor reimburse you the full amount of lost incentive payments? Or do you just get reimbursed for the cost of the software? You shouldn’t purchase a system based on this guarantee alone.

Five Key Questions to Ask Vendors

To help you avoid thse pitfalls, we put together a list of 5 questions to ask vendors. Answering these will put you in a good position to become eligible for incentive payments.

  1. Which certification does the EHR have: CCHIT, KLAS or ONC-ATCB? You must use an EHR that is ONC-ATCB certified in order to be eligible for incentive payments.
  2. Which product version has been certified? Ask the vendor for complete details of their ONC-ATCB 2011/2012 certification, including: product name and version, date certified, unique product identification number, the criteria for which they are certified, and the clinical quality measures for which they were tested.
  3. Does the vendor have certification for a complete EHR or an EHR module? If module, you will need to use more than one to be eligible for incentive payments. The ONC has created a handy website that allows you to build a list of EHR modules that meet 100% of ONC criteria.
  4. Will the vendor resubmit their EHR for final certification in 2012? The current certification is temporary and only lasts through 2011. Make sure your vendor has plans to reapply in 2012, and find out if they will certify a complete EHR or just a module.
  5. Are you purchasing through a reseller or other business partner that renamed the product? If so, make sure the renamed product has been approved by the ONC-ATCB. Even if it is the same version with identical features and functionality, it won’t make their Certified HIT Products List unless the original vendor reports it to an ONC-ATCB.

This article was written by Houston Neal of Software Advice, a free online resource that presents reviews and comparisons of electronic medical record software. The original article can be viewed at Playing Games for ONC Certification.

InfoGard Newest EHR Certifying Body

November 15, 2010 By 2 Comments

According to a report in Health Data Management magazine, InfoGard Laboratories has been selected by ONCHIT (Office of the National Coordinator for Health Information Technology) as the latest entity for certifying EHR (electronic health records) systems. Based in San Luis Obispo, California, InfoGard, a federally accredited IT security testing laboratory since 1995, joins current certifiers CCHIT and the Drummond Group.

Which EMR Systems are Certified?

October 4, 2010 By 1 Comment

The Certification Commission for Health Information Technology (CCHIT), one of the two entities approved for certifying electronic health records (EHR) systems, has just announced the first wave of EHR/EMR products (33 for now) officially achieving Stage 1 certification.

The ONC-ATCB 2011/2012 certification program tests and certifies that [a particular] EHR technology is capable of meeting the 2011/2012 criteria approved by the Secretary of Health and Human Services (HHS). The certifications include Complete EHRs, which meet all of the 2011/2012 criteria for either eligible provider or hospital technology and EHR Modules, which meet one or more – but not all – of the criteria. [This certification] does not represent an endorsement of the certified EHR technology by the U.S. Department of Health and Human Services nor does it guarantee the receipt of incentive payments.

EHR Certifying Bodies Announced

September 13, 2010 By 2 Comments

The Office of the National Coordinator for Information Technology (ONCHIT) has announced the first two companies that have been authorized to test and certify EHR (electronic health records) systems, according to a report by the American Academy of Family Practice.

CCHIT (The Certification Commission for Health Information Technology), one of the entities, is no big surprise to anyone who has been following this topic. The other entity, the Drummond Group Inc., may be less familiar to many. The Austin, Texas, based firm says it has been “working diligently for many months to meet the stringent criteria set forth by the ONC[HIT] to become certified as an ATCB (authorized testing and certification body).”

For those critics who complained that CCHIT was going to monopolize the certification process, this may come as welcome news. But there are still some small EMR vendors who fear they will be locked out of the market.

The Meaning of Meaningful Use of EMR

October 27, 2009 By 7 Comments

If you talk to anyone who is involved in the electronic medical records (EMR) industry, one of the biggest points of discussion is what is known as “Meaningful Use of EMR.” which way.jpgWhat started as a well-intentioned (by some) effort to establish standards for EMR software systems has morphed into political jockeying by corporations, consumer watchdogs, and others.

The US Dept of Health and Human Services (HHS) outlined these criteria for Meaningful Use of EMR:
1)    Improve quality, safety, efficiency, and reduce health disparities
2)    Engage patients and families
3)    Improve care coordination
4)    Improve population and public health
5)    Ensure adequate privacy and security protections for personal health information

And although each of these has defined goals followed by specific objectives and measures for the years 2011, 2013, and 2015, these still sound a bit ambiguous. Many industry experts, however, expect these to be more fine-tuned as the dates approach, but medical practices will have to stay informed to keep ahead of the curve.

Financial Incentives

As part of the ARRA (American Recovery and Reinvestment Act of 2009), financial incentives will be given to those physicians whose practices demonstrate “meaningful use” beginning January, 2011.

The incentive payment, according to CMS, is equal to 75% of Medicare-allowable charges for covered services in a given year, and maxes out as follows:

  • Year 1 – $15,000
  • Year 2 – $12,000
  • Year 3 – $8,000
  • Year 4 – $4,000
  • Year 5 – $2,000

For those practices who are early adopters of the technology and hit the threshold for meaningful use in 2011 or 2012, the first year payment would be $18,000. Note that this only applies to Medicare; there are additional incentives for healthcare providers who have a certain threshold of Medicaid patients and/or who practice in a rural area. The threshold for office-based pediatricians is lower, and so they would be more likely to qualify for those additional funds.

SoftwareAdvice

[table courtesy of SoftwareAdvice.com]

Even considering the fact that EMR implementation may cost anywhere from $10,000 to $50,000 per provider, these incentives would certainly make that investment more palatable.

Those practices that procrastinate, however, will be penalized with cuts in Medicare and Medicaid payments:

  • 2015 – 1%
  • 2016 – 2%
  • 2017 – 3%
  • 2020 – 5% (maximum reduction)

So, how do you know if you qualify? According to the health IT blog NetDoc, to be a “meaningful EHR user”, a physician must satisfy three criteria:

  1. Must use “certified EHR [EMR] technology”
  2. Must demonstrate that the certified EHR technology is connected in such a way that it provides for the electronic exchange of health  information to improve the quality of health care, such as promoting the coordination of care (using HL7 or XML standards)
  3. Must submit information on clinical quality measures specified by HHS (such as PQRI)

Some physicians have told me that because there isn’t a final definition of what is considered “certified EHR technology” they are just going to wait. Big mistake. Most health care IT experts working on and advising on this issue feel fairly strongly that the Office of the National Coordinator for Health Information Technology (ONCHIT) will set CCHIT (Certification Commission for Health Information Technology) criteria as the standard for EMR certification.

CCHIT is a non-profit organization funded by various corporations and groups such as the American College of Physicians and the American Academy of Family Physicians, and was recognized by the US Dept of Health and Human Services (HHS) as a certifying body in 2006.

Some critics, however, charge that CCHIT is a shill for the Healthcare Information and Management Systems Society (HIMSS), the healthcare industry’s membership organization focused on healthcare IT. Although made up of both corporate and individual members, these critics feel that their goal is to corner the market for certain major EMR players. Nevertheless, unless or until there is an alternative, most EMR vendors are using CCHIT certification as the benchmark.

In addition to the EMR certification criteria, the ONCHIT is expected to adopt an initial set of standards and implementation specifications by the end of the year 2009.

Timeline

So, is too late to implement EMR in your practice and still qualify for the financial incentives? Well, that depends on the size of your practice, type of specialty, and how motivated your doctors and staff are to go paperless. Just don’t expect to run down to Office Depot, buy an EMR program and launch it the next day (although there is talk about WalMart getting into the EMR business, but we’ll leave that story for another day…)

According to MBA HealthGroup, these are some reasonable time frames to expect for EMR Implementation:

  • Stage 1 – up to 6 months – researching vendors, getting buy-in, setting up an EMR committee, checking out demos, and making a final decision on the EMR system
  • Stage 2 – up to 5 months –  time it will take to actually ‘go live’. In the meantime, adapting workflow to EMR system you chose, ordering hardware, and standardizing processes
  • Stage 3 – between 6 and 12 months – amount of time it will likely take to achieve “meaningful use”, which includes ePrescribing, documenting electronically, and ability to report certain items (which are still being determined)

MBA HealthBlog

[timeline courtesy of MBA HealthBlog]

Smaller groups and solo doctors may be able to purchase a more basic, “out-of-the-box” EMR system and more quickly adapt their workflow to the system, rather than vice versa in the case of larger medical practices. But, the one thing you can count on with EMR implementation is that you can’t count on anything – that is why some sort of timeline is important [see EMR Implementation Rollout].

What this boils down to is that those practices that have already started implementing EMR will have a good shot at getting those higher financial incentives. On the other hand, physicians who have been wishing that the whole idea of EMR was just a fleeting fad may not only miss out on these incentives but may also face cuts in their reimbursement.

Questions? Comments? Post them below