Convention Q and A: Deciphering EHR Incentive Attestation and Certification

Certification alone does not guarantee that a product will allow providers to achieve attestation to meaningful use. Additional research and other steps toward customization may be necessary as well.

With the Centers for Medicare and Medicaid Services’ (CMS) release of the final rule for the stage 2 meaningful use Electronic Health Record Incentive Program in late August—and stage 3 on the way—it’s more important than ever for providers to understand not only how EHR systems must be used in order to meet meaningful use objectives, but how products are evaluated for certification as well.

On Tuesday, October 2, Michelle Knighton, MBA, RHIA, healthcare testing manager for ICSA Labs, and Amanda King, MHIIM, RHIA, health IT specialist for Tennessee’s Regional Extension Center, will present a session at the AHIMA Convention and Exhibit in Chicago, IL that represents both sides of meaningful use: certification and attestation.

In the below Q and A, Knighton discusses the certification process for EHR products, strategies for implementing and working with the systems, and important considerations to keep in mind when researching systems.

How does the certification process for EHR products connect with the objectives a provider must meet when attesting for meaningful use stage 2?

Knighton: The certification criteria are designed with the intent to support a provider attempting to meet meaningful use. Under the (Office of the National Coordinator for Health IT) ONC health IT certification program and new 2014 edition certification criteria, we’ve seen both ONC and CMS working more closely to better align the objectives a provider must meet when attesting for stage 2 meaningful use and the functions an EHR product must demonstrate for certification.

Although the final rule for certification was published in the Federal Register on September 4 with an effective date of October 4, the test procedures that prescribe how health IT testing labs must assess EHR products aren’t expected to be finalized in full until late December or early January. We’ll have a better sense of the disparities between how products are tested and how providers are required to meet meaningful use once those test procedures are approved.

What can providers do to bridge the gap and still deliver high quality care when an EHR system or vendor doesn’t fully meet organization needs?

Knighton: Leveraging EHR technology to improve the quality of care being provided is one of the core missions of the entire meaningful use program. To help bridge the gap but still deliver high quality care, providers should plan on monitoring current workflow issues to develop best practices as part of a comprehensive transition plan to meet the stage 2 requirements. Providers should also plan on talking to their EHR vendors about any obstacles they see to becoming a meaningful user. Chances are the vendor will appreciate the opportunity to improve the system.

The updated definition of a certified EHR technology also lends some flexibility. Stage 2 providers only will be required to possess EHR technology that combined has been certified to the 2014 edition certification criteria that meets the definition of a “base EHR” (limited to 20 core criteria) and supports the objectives and measures needed to successfully report clinical quality measures. If a system doesn’t fully meet the organization’s needs, likely the provider will be able to find a system that does.

Many EHRs are not ready to go out of the box. Instead, organizations must prepare to spend time in the implementation process to ensure the product is implemented in such a way that best meets their needs. It’s important to remember that although certification testing assesses the capabilities of the EHR, it is during the implementation process where providers have the opportunity to fine-tune the product’s capabilities for their organization.

What should providers look for when evaluating and purchasing an EHR system that they might not immediately expect?

Knighton: In many ways, the new 2014 edition certification criteria and closer alignment with the CMS objectives/measures should provide better assurance to providers that EHRs are being tested and certified in a way that will help them meet stage 2 meaningful use requirements.

Other high-level things to look for during the EHR selection process include:

  1. There are many certified products, so be sure to check the Certified Health IT Product List (CHPL) to ensure that the product has been certified to the specific criteria that the provider needs to meet meaningful use.
  2. Understanding that certification is product name- and version-specific. If the product name/version in the selection process is not listed on the CHPL, it is not certified.
  3. Sometimes it can be helpful to understand how an EHR is tested to better understand the base functionality it needs to attain certification. The ONC-approved test procedures are the best resource for this. For example, if a product was certified to the 2011 edition criterion “medication reconciliation,” it is important to know that reconciliation is not part of the test process. As an accredited health IT test lab, we always encourage vendors to compete above the bar. However, at the end of the day, certification should be seen as verification that products meet the minimum requirements as defined by the test procedure.
  4. Due diligence is important—make sure you talk to peers, check references, and ask lots of questions about the training process and upgrade/customization costs.

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